Text

Supplement to License Amendment Request 278. Incorporate Advanced Fuel Products. Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles
	ML24040A190
Person / Time
Site:	Turkey Point
Issue date:	02/09/2024
From:	Deboer D; Florida Power & Light Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24040A189	List: ML24040A190;
References
	L-2024-008
	Download: ML24040A190 (1)
	v • d • e

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE:

Turkey Point Nuclear Generating Station, Unit 3 and 4 Docket Nos. 50-250 and 50-251 Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 February 9, 2024 L-2024-008 10 CFR 50.90 Supplement to License Amendment Request 278. Incorporate Advanced Fuel Products. Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles

References:

1.

Florida Power & Light letter L-2023-078, License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles, November 15, 2023 (ADAMS Accession No. ML23320A029)

2.

Westinghouse Electric Company Topical Report WCAP-18888-P/NP "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 24 Month Fuel Cycle", January 2024

3.

Westinghouse Electric Company Topical Report WCAP-17070-P/NP, Revision 1, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 (Power Uprate to 2644 MWt - Core Power)," June 2011 (ADAMS Accession No. ML11174A168, ML11174A166)

In Reference 1, Florida Power & Light Company (FPL) requested amendments to Subsequent Renewed Facility Operating Licenses (SRFOLs) Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Generating Station, Units 3 and 4 (Turkey Point), respectively. The proposed license amendments revise the Turkey Point licensing basis by incorporating advanced fuel featur_es (e.g., AXIOM cladding, ADOPT' fuel pellets, and a PRIME' fuel skeleton), extending Technical Specification (TS) surveillance intervals, modifying TS Allowable Values (AVs) and a Trip Setpoint, and conforming changes to the Updated Final Safety Analysis Report to facilitate a transition to 24-month fuel cycles.

FPL submits this supplement to Reference 1 which expands the request for extended TS surveillance intervals to include three additional TS instrument functions and conforming changes to the Turkey Point TS and TS Bases pages. In addition, FPL submits Westinghouse Electric Company Topical Report WCAP-18888-P/NP (Reference 2), which broadens the setpoint methodology previously described in WCAP-17070-P (Reference 3) to all Turkey Point reactor trip system (RTS) and engineered safety feature actuation system (ES FAS) instrument functions in support of a transition to 24-month fuel cycles. to this letter provides FPL's supplemental evaluation of the proposed change. Attachment 1 to Enclosure 1 provides the Turkey Point TS pages marked up to show the amended proposed TS changes. to Enclosure 1 provides the Turkey Point TS Bases pages marked up to show the amended proposed TS Bases changes. The TS Bases markups are provided for information only and will be incorporated in accordance with the Turkey Point TS Bases Control Program upon implementation of the approved license amendments. provides the proprietary version of WCAP-18888 (Reference 2). Enclosure 2 contains information that Westinghouse Electric Company LLC (Westinghouse) considers to be proprietary in nature.

Pursuant to 10 CFR 2.390(a)(4), FPL requests the proprietary information be withheld from public disclosure. Enclosure 3 provides a non-proprietary version of the information provided in Enclosure 2.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2024-008 Page 2 of 2 provides the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-24-002 affidavit supporting the proprietary withholding request for Enclosure 2. The request is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission ("Commission") and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Accordingly, FPL requests that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations. Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-24-002 and be addressed to Camille T. Zozula, Manager, Regulatory Compliance & Corporate Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive. Suite 165, Cranberry Township, Pennsylvania 16066.

FPL has determined that the proposed change does not alter the conclusions of the significant hazards consideration originally proposed pursuant to 10 CFR 50.92(c), and there are no significant environmental impacts associated with this change. The Turkey Point Onsite Review Group has reviewed the proposed license amendments. In accordance with 10 CFR 50.91(b)(1 ), a copy of the proposed license amendments is being forwarded to the State designee for the State of Florida.

This letter contains no regulatory commitments.

Should you have any questions regarding this submittal, please contact Mr. Kenneth Mack, Fleet Licensing Manager at 561-904-3635.

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

Executed on the 9th day of February 2024.

O~tJ,&_,,.-..-/

Daniel DeBoer Vice President, Nuclear Florida Power & Light Company cc:

USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Generating Station USNRC Senior Resident Inspector, Turkey Point Nuclear Generating Station Mr. Clark Eldredge, Florida Department of Health (Enclosure 1 and Attachments only)

Enclosures:

(1 )

Supplement to License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals, and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles (2)

WCAP-18888-P, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 24 Month Fuel Cycle", January 2024 (Proprietary)

(3)

WCAP-18888-NP, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 24 Month Fuel Cycle", February 2024 (Non-Proprietary)

(4)

Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-24-002

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 Page 1 of 6 Turkey Point Nuclear Plant Unit 3 and Unit 4 Supplement to License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals, and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles

1.0 BACKGROUND

............................................................................................................................... 2

2.0 DESCRIPTION

OF CHANGE.......................................................................................................... 2

3.0 TECHNICAL EVALUATION

............................................................................................................ 5

4.0 REFERENCES

................................................................................................................................. 5 Attachments:

1.

Supplemental Turkey Point Technical Specification Pages (markup)

2.

Supplemental Turkey Point Technical Specification Bases Pages (markup for information only)

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 Page 2 of 6

1.0 BACKGROUND

In Reference 4.1, Florida Power & Light Company (FPL) requested amendments to Renewed Facility Operating Licenses (RFOLs) Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Generating Station, Units 3 and 4 (Turkey Point), respectively, to facilitate a transition to 24-month operating cycles.

FPL submits this supplement to Reference 4.1 which expands the request for extended TS surveillance intervals to include three additional TS instrument functions and conforming changes to the Turkey Point TS and TS Bases pages. In addition, FPL submits Westinghouse Electric Company Topical Report WCAP-18888-P/NP (Reference 4.2), which broadens the setpoint methodology previously described in WCAP-17070-P (Reference 4.3) to all Turkey Point reactor trip system (RTS) and engineered safety feature actuation system (ESFAS) instrument functions in support of a transition to 24-month fuel cycles.

2.0 DESCRIPTION

OF CHANGE As described in Reference 4.1, during the effort to extend the selected Surveillance Frequencies (SFs) using the guidance provided in Generic Letter (GL) 91-04 (Reference 4.4), it was determined that the setpoint methodology for the Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) functions that were not updated during the Extended Power Uprate (EPU) required an update to Regulatory Guide (RG) 1.105 Revision 3 (Reference 4.5). This resulted in changes to the instrument function Allowable Values and one setpoint change, as described in Reference 4.1, Attachment 4, and identified in Table C-3: Summary of Allowable Value and Trip Setpoint Changes of Reference 4.1, Attachment 4.

This supplement adds three additional RTS and ESFAS functions (listed below) to Reference 4.1,, Table C-3, based on RG-1.105, Revision 3, in support of a maximum surveillance interval of 30 months. In accordance with the guidance of GL 91-04 for instrument calibration interval extensions, a comparison of the projected drift errors for the three additional RTS and ESFAS functions over the extended calibration interval was completed using the drift values from the setpoint evaluations. The setpoint evaluations conducted in support of extending the calibration surveillance intervals for these functions identified the TS Allowable Value changes listed below.

No change to plant safety analyses (i.e., analytical limit or other design basis assumption) is required to support these Allowable Value changes.

Table 3.3.1-1 Reactor Trip System Instrumentation, Functional Unit (FU) 3, Intermediate Range, Neutron Flux o

The Allowable Value is revised from 31% RTP to 25.6% RTP.

Table 3.3.1-1 Reactor Trip System Instrumentation FU-4 Source Range, Neutron Flux o

The Allowable Value is revised from 1.40E+05 to 1.05E+05 CPS.

Table 3.3.2-1 ESFAS Instrumentation FU-1e, Safety Injection - High Differential Pressure Between Steam Line Header & any SG o

The Allowable Value is revised from 114 psi to 107 psi.

In addition, WCAP-18888-P/NP (Reference 4.2) in Enclosures 2 and 3 to this supplement is provided which replaces WCAP-17070-P (Reference 4.3) as the setpoint uncertainty reference in the Turkey Point UFSAR and in the TS Bases, as shown in Attachment 2 to this enclosure. WCAP-18888-P/NP summarizes the RTS and ESFAS setpoint uncertainty calculations for 24-month

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 Page 3 of 6 operating cycles. WCAP-18888-P/NP applies the same setpoint methodology as WCAP-17070-P but for all RTS and ESFAS instrument functions, including those not previously revised for the EPU.

Additionally, the TS markup pages of Reference 4.1 Enclosure 1, Attachment 1 Turkey Point Units 3&4 Technical Specification Pages (Markup) inadvertently deleted the following sentence from Footnote c of TS Table 3.3.1-1 and Footnote h of Table 3.3.2-1:

Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance.

This supplement revises Reference 4.1 by retaining the above sentence in Footnote c of TS Table 3.3.1-1 and Footnote h of Table 3.3.2-1, as shown in Attachments 1 and 2 to this enclosure.

In addition, Reference 4.1, Attachment 4, Table C-1: Applicable Instrumentation is revised to reflect corrections to as-installed equipment. The proposed changes to Reference 4.1, Attachment 4, Tables C-1 and C-3 are identified below:

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 Enclosure 1 Page 4 of 6 Table C1: Applicable Instrumentation (revised)

Surveillance Requirement Tech Spec Section /

Function Description Manufacturer Model Number \\

Description Range SR 3.3.1.10 Table 3.3.1-1, Function 7 Perform CHANNEL Calibration.

Pressurizer Pressure - Low Rosemount

3154NA6 1500 to 2500 psig SR 3.3.1.10 Table 3.3.1-1, Function 10 Perform CHANNEL Calibration.

Pressurizer Pressure - High Rosemount

3154NA6 1500 to 2500 psig SR 3.3.2.6 Table 3.3.2-1, Function 1.d Perform CHANNEL Calibration.

Safety Injection - Pressurizer Pressure - Low Rosemount

3154NA6 1500 to 2500 psig

Change: 1154SH9RB / 3154NA6 was replaced with 3154NA6.

Table C-3: Summary of Allowable Value and Trip Setpoint Changes (Additional instrument function changes)

Table 3.3.1-1 Reactor Trip System Instrumentation Functions Current TS AV Units Trip Setpoint Units 24 Month TS AV Units Remarks 3

Intermediate Range, Neutron Flux 31%

RTP

25%

RTP 25.6%

RTP AV change due to WCAP-17070-P setpoint uncertainty methodology change.

4 Source Range, Neutron Flux 1.40E+05 cps

1.00E+05 cps 1.05E+05 cps AV change due to WCAP-17070-P setpoint uncertainty methodology change.

Table 3.3.2-1 ESFAS Instrumentation Functions Current TS AV Units Trip Setpoint Units 24 Month TS AV Units Remarks 1

Safety Injection 1e High Differential Pressure Between Steam Line Header

& any & SG 114 psi

100 psig

107 psig AV change due to WCAP-17070-P setpoint uncertainty methodology change.

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 Page 5 of 6

3.0 TECHNICAL EVALUATION

FPL proposes to revise the Allowable Values for the specified functions in TS Table 3.3.1-1 and Table 3.3.2-1 described above consistent with the methodology for the trip setpoints affected by the EPU that were previously approved for Turkey Point Units 3 and 4 (Reference 4.6). The proposed changes to the TS Allowable Values are based on the rack calibration accuracy (RCA) which is the two-sided calibration tolerance of the process racks. This conservatively results in Allowable Values closer to the Trip Setpoint values, which would require Channel Operational Tests (COTs) to be performed closer to the nominal trip setpoint. Therefore, the proposed change would provide an earlier indication of a channel deviating from the required setpoint tolerance prior to the next scheduled channel calibration.

The revised Allowable Values for the three additional instrument functions differ from the respective Trip Setpoint by an amount greater than or equal to the expected instrument rack channel tolerances. Trip Setpoints, in conjunction with the use of calibration tolerances together with the requirements of the Allowable Values ensure that the consequences of Design Basis Accidents (DBAs) will be acceptable.

The impact of instrument drift for the three additional TS functions was evaluated for the proposed calibration SR interval change from 18 to 24 months. As a result of the drift evaluation, Turkey Point Units 3 and 4 instrumentation setpoint and uncertainty calculations were revised to reflect the proposed calibration SR interval changes. The affected calibration surveillance procedures will be revised as part of implementation, prior to the first application of SRs with a 24-month frequency.

The sentence that was incorrectly shown to be deleted in the TS markups of TS Table 3.3.1-1 Footnote c and Table 3.3.2-1 Footnote h should be retained because it is conservative with regard to the setpoint calculation methodology in References 4.2 and 4.3 and consistent with the Turkey Point surveillance procedures.

Reference 4.1, Attachment 4, Table C-1: Applicable Instrumentation corrections are provided to correct the as-installed equipment models. There are no changes to the TS Allowable Values or trip setpoints as a result of these changes.

4.0 REFERENCES

4.1 Florida Power & Light letter L-2023-078, License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles, November 15, 2023 (ADAMS Accession No. ML23320A029).

4.2 Westinghouse Electric Company Topical Report WCAP-18888-P/NP Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 24 Month Fuel Cycle, January/February 2024.

4.3 Westinghouse Electric Company Topical Report, WCAP-17070-P, Revision 1, Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 (Power Uprate to 2644 MWt - Core Power), June 2011.

4.4 Generic Letter (GL) 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, April 2, 1991, (ADAMS Accession No. ML031140501) 4.5 RG 1.105, Revision 3 Setpoints for Safety-Related Instrumentation, December 1999.

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 Page 6 of 6 4.6 Letter from Jason C. Paige (USNRC) to Mano Nazar (FPL), Turkey Point Units 3 and 4 -

Issuance of Amendments Regarding Extended Power Uprate (TAC Nos. ME4907 and ME4908), June 2012 (ADAMS Accession No. ML11293A365).

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 ATTACHMENT 1 Turkey Point Units 3 & 4 Technical Specification Pages (Markup)

(8 pages follow)

RTS Instrumentation 3.3.1 Turkey Point Unit 3 and Unit 4 3.3.1-11 Amendment Nos. 297 and 290 Table 3.3.1-1 (page 1 of 10)

Reactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE TRIP SETPOINT 1.

Manual Reactor Trip 1,2 2

B SR 3.3.1.12 NA NA 3(a),4(a),5(a) 2 C

SR 3.3.1.12 NA NA 2.

Power Range Neutron Flux a.

High 1,2 4

D SR 3.3.1.1 SR 3.3.1.2 SR 3.3.1.7(b)(c)

SR 3.3.1.9(b)(c) 108.6% RTP 108.0% RTP b.

Low 1(d),2 4

E SR 3.3.1.1 SR 3.3.1.8(f)(g)

SR 3.3.1.9(f)(g) 28% RTP 25% RTP 3.

Intermediate Range Neutron Flux 1(d),2 2

F, G SR 3.3.1.1 SR 3.3.1.8(f)(g)

SR 3.3.1.9(f)(g) 31% RTP 25% RTP 4.

Source Range Neutron Flux 2(e) 2 H, I SR 3.3.1.1 SR 3.3.1.8(f)(g)

SR 3.3.1.9(f)(g) 1.4 E5 cps 1.0 E5 cps 3(a),4(a),5(a) 2 I, J SR 3.3.1.1 SR 3.3.1.7(f)(g)

SR 3.3.1.9(f)(g) 1.4 E5 cps 1.0 E5 cps (a)

With Rod Control System capable of rod withdrawal or one or more rods not fully insert.

(b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.

(d)

Below the P-10 (Power Range Neutron Flux) interlocks.

(e)

Below the P-6 (Intermediate Range Neutron Flux) interlocks.

(f)

The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

(g)

If the instrument channel setpoint is less conservative than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable.

25.6 1.05 Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence.

1.05

S

S c=J

S -

S CJ

S -

S CJ

S -

S

RTS Instrumentation 3.3.1 Turkey Point Unit 3 and Unit 4 3.3.1-12 Amendment Nos. 297 and 290 Table 3.3.1-1 (page 2 of 10)

Reactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE TRIP SETPOINT 5.

1,2 3

E SR 3.3.1.1 SR 3.3.1.3 SR 3.3.1.6 SR 3.3.1.7(b)(c)

SR 3.3.1.10(b)(c)

Refer to Note 2 (Page 3.3.1-18)

Refer to Note 1 (Page 3.3.1-17) 6.

1,2 3

E SR 3.3.1.1 SR 3.3.1.7(b)(c)

SR 3.3.1.10(b)(c)

Refer to Note 4 (Page 3.3.1-20)

Refer to Note 3 (Page 3.3.1-19) 7.

Pressurizer Pressure

- Low 1(h) 3 L

SR 3.3.1.1 SR 3.3.1.7(f)(g)

SR 3.3.1.10(f)(g) 1817 psig 1835 psig 8.

Pressurizer Pressure

- High 1,2 3

L SR 3.3.1.1 SR 3.3.1.7(f)(g)

SR 3.3.1.10(f)(g) 2403 psig 2385 psig 9.

Pressurizer Water Level - High 1(h) 3 L

SR 3.3.1.1 SR 3.3.1.7(f)(g)

SR 3.3.1.10(f)(g) 92.2%

92.0%

10. Reactor Coolant Flow - Low a.

Single Loop 1(i) 3 per loop L

SR 3.3.1.1 SR 3.3.1.7(b)(c)

SR 3.3.1.10(b)(c) 89.6%

90.0%

(b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.

(f)

The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

(g)

If the instrument channel setpoint is less conservative than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable.

(h)

Above the P-7 (Low Power Reactor Trips Block) interlock.

(i)

Above the P-8 (Power Range Neutron Flux) interlock.

Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence.

1830 2390 Overtemperature Lff Overpower Lff D

s--

s

RTS Instrumentation 3.3.1 Turkey Point Unit 3 and Unit 4 3.3.1-13 Amendment Nos. 297 and 290 Table 3.3.1-1 (page 3 of 10)

Reactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE TRIP SETPOINT

10. Reactor Coolant Flow - Low (continued)

b. Two Loops 1(j) 3 per loop L

SR 3.3.1.1 SR 3.3.1.7(b)(c)

SR 3.3.1.10(b)(c) 89.6%

90.0%

11. Steam Generator (SG) Water Level -

Low Low 1,2 3 per SG L

SR 3.3.1.1 SR 3.3.1.7(b)(c)

SR 3.3.1.10(b)(c) 15.5%

16.0%

12. SG Water Level -

Low 1,2 2 per SG L

SR 3.3.1.1 SR 3.3.1.7(b)(c)

SR 3.3.1.10(b)(c) 15.5%

16.0%

Coincident with Steam Flow/Feedwater Flow Mismatch 1,2 2 per SG L

SR 3.3.1.1 SR 3.3.1.7(b)(c)

SR 3.3.1.10(b)(c) 20.7%

below rated steam flow 20.0% below rated steam flow

13. Undervoltage -

4.16 kV Buses A and B 1(h) 2 per bus L

SR 3.3.1.10(f)(g) 69% bus voltage 70% bus voltage 14 Underfrequency RCPs Breakers Open 1(h) 2 per bus N

SR 3.3.1.10(f)(g) 55.9 Hz 56.1 Hz (b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.

(f)

The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

(g)

If the instrument channel setpoint is less conservative than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable.

(h)

Above the P-7 (Low Power Reactor Trips Block) interlock.

(j)

Above the P-7 (Low Power Reactor Trips Block) interlock and below the P-8 (Power Range neutron Flux) interlock.

Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence.

56.08

RTS Instrumentation 3.3.1 Turkey Point Unit 3 and Unit 4 3.3.1-14 Amendment Nos. 297 and 290 Table 3.3.1-1 (page 4 of 10)

Reactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE TRIP SETPOINT

15. Turbine Trip a.

Emergency Trip Header Pressure 1(h) 3 L

SR 3.3.1.10(b)(c)

SR 3.3.1.13 901 psig 1000 psig b.

Turbine Stop Valve Closure 1(h) 2 L

SR 3.3.1.10 SR 3.3.1.13 Fully Closed Fully Closed

16. Safety Injection (SI)

Input from Engineered Safety Feature Actuation System (ESFAS) 1,2 2 trains O

SR 3.3.1.12 NA NA

17. Reactor Trip System Interlocks a.

Intermediate Range Neutron Flux, P-6 2(e) 2 P

SR 3.3.1.9(f)(g)

SR 3.3.1.11(f)(g) 6E-11 amp Nominal 1E-10 amp b.

Low Power Reactor Trips Block, P-7

1) P10 Input 1

4 Q

SR 3.3.1.9(f)(g)

SR 3.3.1.11(f)(g) 13% RTP Nominal 10% RTP

2) Turbine Inlet Pressure.

1 2

Q SR 3.3.1.9(f)(g)

SR 3.3.1.11(f)(g) 13%

turbine power Nominal 10% turbine power (b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.

(e)

Below the P-6 (Intermediate Range Neutron Flux) interlocks.

(f)

The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

(g)

If the instrument channel setpoint is less conservative than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable.

(h)

Above the P-7 (Low Power Reactor Trips Block) interlock.

Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence.

ESFAS Instrumentation 3.3.2 Turkey Point Unit 3 and Unit 4 3.3.2-7 Amendment Nos. 297 and 290 Table 3.3.2-1 (page 1 of 7)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE TRIP SETPOINT 1.

Safety Injection a.

Manual Initiation 1,2,3,4 2

B SR 3.3.2.5 NA NA b.

Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains C

SR 3.3.2.2 NA NA

c. Containment Pressure - High 1,2,3 3

E SR 3.3.2.2 SR 3.3.2.6(b)(c) 4.5 psig 4.0 psig d.

Pressurizer Pressure - Low 1,2,3(a) 3 E

SR 3.3.2.1 SR 3.3.2.3(b)(c)

SR 3.3.2.6(b)(c) 1712 psig 1730 psig e.

High Differential Pressure Between Steam Line Header and any Steam Generator (SG) 1,2,3(a) 3 per steam line E

SR 3.3.2.1 SR 3.3.2.3(b)(c)

SR 3.3.2.6(b)(c) 114 psi 100 psi (a)

Above the P-11 (Pressurizer Pressure) interlock.

(b)

The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

(c)

If the instrument channel setpoint is less conservative than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable.

107 1725 I

~

D

ESFAS Instrumentation 3.3.2 Turkey Point Unit 3 and Unit 4 3.3.2-8 Amendment Nos. 297 and 290 Table 3.3.2-1 (page 2 of 7)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE TRIP SETPOINT 1.

Safety Injection (continued) f.

Steam Line Flow -

High 1,2,3(d) 2 per steam line E

SR 3.3.2.1 SR 3.3.2.3(g)(h)

SR 3.3.2.6(g)(h)

(e)

(f)

Coincident with Tavg - Low 1,2,3(d) 1 per loop E

SR 3.3.2.1 SR 3.3.2.3(b)(c)

SR 3.3.2.6(b)(c) 542.5°F 543.0°F g.

Steam Line Flow -

High 1,2,3(d) 2 per steam line E

SR 3.3.2.1 SR 3.3.2.3(g)(h)

SR 3.3.2.6(g)(h)

(e)

(f)

Coincident with Steam Generator Pressure - Low 1,2,3(d) 1 per SG E

SR 3.3.2.1 SR 3.3.2.3(g)(h)

SR 3.3.2.6(g)(h) 607 psig(i) 614 psig(i) 2.

Containment Spray a.

Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains C

SR 3.3.2.2 NA NA (b)

The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

(c)

If the instrument channel setpoint is less conservative than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable.

(d)

Above the (Tavg - Low) interlock.

(e)

(f)

(g)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(h)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.

(i)

Time constants used in the lead/lag controller are t1 50 seconds and t2 5 seconds.

Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence.

542.7 Less than or equal to a function defined as ~P correstm1r,mnn-"TrT"Zl'T"'7"'J~=rnrnn,][7"'!:ITTil"T,;""rn?:lrrr-!:lffl~n-t-ea ing linearly from 20% load to 114.4% steam flow at 100% load.

Less than or equal to a function defined as ~P corresponding to 40.0% steam flow at 0% load, and increas ng linearly from 20% load to 114.0% steam flow at 100% load.

ESFAS Instrumentation 3.3.2 Turkey Point Unit 3 and Unit 4 3.3.2-11 Amendment Nos. 297 and 290 Table 3.3.2-1 (page 5 of 7)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE TRIP SETPOINT 4.

Steam Line Isolation (continued) d.

Steam Line Flow

- High 1,2(j),3(j) 2 per steam line I

SR 3.3.2.1 SR 3.3.2.3(g)(h)

SR 3.3.2.6(g)(h)

(e)

(f)

Coincident with Tavg - Low 1,2(j),3(j) 1 per loop E

SR 3.3.2.1 SR 3.3.2.3(b)(c)

SR 3.3.2.6(b)(c) 542.5°F 543.0°F

e. Steam Line Flow

- High 1,2(j),3(j) 2 per steam line I

SR 3.3.2.1 SR 3.3.2.3(g)(h)

SR 3.3.2.6(g)(h)

(e)

(f)

Coincident with Steam Generator Pressure - Low 1,2(j),3(j) 1 per SG I

SR 3.3.2.1 SR 3.3.2.3(g)(h)

SR 3.3.2.6(g)(h) 607 psig(i) 614 psig(i)

(b)

The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.

(c)

If the instrument channel setpoint is less conservative than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable.

(e) g linearly (f) increasing linearly (g)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(h)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.

(i)

Time constants used in the lead/lag controller are t1 50 seconds and t2 5 seconds.

(j)

Except when all MSIVs are closed and deactivated.

Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence.

542.7 Less than or equal to a function defined as L'1P corresponding to 41.2% steam flow at 0% load, and increasin from 20% load to 114.4% steam flow at 100% load.

Less than or equal to a function defined as L'1P corresponding to 40.0% steam flow at 0% load, and from 20% load to 114.0% steam flow at 100% load.

ESFAS Instrumentation 3.3.2 Turkey Point Unit 3 and Unit 4 3.3.2-12 Amendment Nos. 297 and 290 Table 3.3.2-1 (page 6 of 7)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE TRIP SETPOINT 5.

Feedwater Isolation a.

Automatic Actuation Logic and Actuation Relays 1,2(k),3(k) 2 trains D

SR 3.3.2.2 NA NA

b.

SG Water Level -

High High 1,2(k),3(k) 3 per SG I

SR 3.3.2.1 SR 3.3.2.3(g)(h)

SR 3.3.2.6(g)(h) c.

Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

6.

Auxiliary Feedwater

a.

Automatic Actuation Logic and Actuation Relays 1,2,3 2 trains D

SR 3.3.2.2 NA NA b.

SG Water Level -

Low Low 1,2,3 3 per SG E

SR 3.3.2.1 SR 3.3.2.3(g)(h)

SR 3.3.2.6(g)(h) c.

Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

d.

Bus Stripping 1,2,3 1 per bus G

SR 3.3.2.4 SR 3.3.2.6 NA See LCO 3.3.5, LOP EDG Start Instrumentation, for Trip Setpoints e.

Trip of all Main Feedwater Pumps Breakers 1,2 1 per breaker H

SR 3.3.2.4 NA NA (g)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(h)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.

(k)

Except when all MFIVs, MFRVs, and associated bypass valves are closed and de-activated or isolated by a closed manual valve.

Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence.

s 80.5%

80.0%

=:: 15.5%

16.0%

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 ATTACHMENT 2 Turkey Point Units 3&4 Technical Specification Bases Pages (Markup for information only)

(15 pages follow)

BASES RTS Instrumentation B 3.

3.1 BACKGROUND

(continued)

WCAP-18888-P, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 and 4 Month Fuel Cycle" safety functions(s)." Relying solely on the Trip Setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the 11as-found" value of a protection channel setting during a surveillance. To ensure the instrument is functioning as predicted, the change in the trip sett,ing since the last test or calibration is verified to be within predefined limits (double-sided acceptance criteria band) and appropriate actions are r---.taJc:en if the change is outside these limits. The acceptance criteria band is derive

~jpt calculation based on the setpoint methodology described m \\'IICJ\\c,P 1274 S, '"Afe&tinghouse SetJ3eint Metheaelegy fer PretosUen &¥&toms TuFkey Point Units a ane 4" (Ref. i),

er: WSAP 17070, "'l!estinghouse Setpoint Methedotegy for ProteelieA Systems Turkey Point Units a aflEl-4!! (Ref *Jli as aJ3plieable.

If the trip setting exceeds the Allowable Va~

the channel is inoperable.

If the change in the trip setting exceeds the predefined limits but the

. setting is conservative with respect to the Allowable Value, and during the surveillance the instrument channel is functioning as expected and can be reset to within the setting tolerance of the Trip Setpoint, then the channel may be returned to service and the condition entered into the corrective action program for further evaluation. However, if during the surveillance the change in the trip setting exceeds the predefined limits and it cannot be determined that the instrument channel is functioning as required, then the instrument is declared inoperable. Thus, verifying the trip setting is within the acceptance criteria band during test or calibration is part of the determination that an instrument is functioning as required.

Therefore, the channel would still be OPERABLE since it would have performed its safety function and the only corrective action required would be to reset the channel within the established calibration tolerance around the Trip Setpoint to account for further drift during the next surveillance interval.

During AOOs, which are those events expected to occur one or more times during the unit life, the acceptable limits are:

1.

The Departure from Nucleate Boiling Ratio (DNBR) shall be maintained above the Safety Limit (SL) value to prevent departure from nudeate boiling (DNB),

2.

Fuel centerline melt shall not occur, and

3.

The RCS pressure SL of 2735 psig shall not be exceeded.

Turkey Point Unit 3 and Unit 4 B 3.3.1-2 Revision No. O

-18888-P (Ref.6)

BASES RTS Instrumentation B 3.

3.1 BACKGROUND

(continued)

Two logic channels are required to ensure no single random failure of a logic channel will disable the RTS. The logic channels are designed such that testing required while the reactor is at power may be accomplished without causing trip. Provisions to allow removing logic channels from service during maintenance are unnecessary because of the logic system*s designed reliability.

Allowable Values and Trip Setpoints The trip setpoints used in the bistables are bas d on analytical limits specified in the safety analyses. The calculatio of the Trip Setpoint specified in Table 3.3.1-1 is such that adequate protection is provided when all sensor and processing time delays ar taken into account. To allow for calibration tolerances, instrumentatio uncertainties, instrument drift, and severe environment errors for those TS channels that must function in harsh environments as defined by 1 0 CFR 50.49 (Ref. 5), the

? ~

specified in Table 3.3.1-1 in he accompanying LCO are Trip Setpoints

!Trip Setpoint conservative with respect to the analytical limi s. A detailed description of the methodology used to calculate the Allowa le Values and Trip Setpoint, including their explicit uncertainties, nd as-left and as-found tolerance bands, is provided in Westinghous apical reports WCAP 12746 (Ref. e) and WCAP 17070 (Ref.7) which incorporates all of the known uncertainties applicable to each channel. A summary description of and reference to the calibration tolerance methodology is provided in UFSAR Section 7.2 (Ref. 2). The magnitudes of these uncertainties are factored into the determination of each Trip Setpoint and corresponding Allowable Value. The trip setpoint entered into the bistable is more conservative than that specified by the Allowable Value to account for measurement errors detectable by the CHANNEL OPERATIONAL TEST (COT). The Allowable Value serves as the Technical Specification OPERABILITY limit for the purpose of the COT.

h The Trip Setpoint is the value at which the bistable is set and is the

~ expected value to be achieved during calibration. The Allowable Value is the LSSS and ensures the safety analysis limits are met during the surveillance interval selected when a channel is adjusted based on stated channel uncertainties. Any bistable is considered to be properly adjusted when the "as-left" Trip Setpoint value is within the calibration tolerance for CHANNEL CALIBRATION uncertainty allowance (i.e., ~ rack calibration and somparator setting uncertainties).

Trip Setpoints, in conjunction with the use of calibration tolerances, together 1,11ith the Fequiremenls of the Allowable 'Jalue ensure that SLs are not violated during AOOs (and that the consequences of DBAs will be acceptable, providing the unit is operated from within the LCOs at the onset of the AOO or OBA and the equipment functions as designed).

Turkey Point Unit 3 and Unit 4 B 3.3.1-5 Revision No. 0

RTS Instrumentation B 3.3.1 Turkey Point Unit 3 and Unit 4 B 3.3.1-9 Revision No. 0 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued)

A trip setpoint may be set more conservative than the Trip Setpoint as necessary in response to plant conditions. However, in this case, the OPERABILITY of this instrument must be verified based on the field setting and not the Trip Setpoint. Failure of any instrument renders the affected channel(s) inoperable and reduces the reliability of the affected Functions.

The LCO generally requires OPERABILITY of four or three channels in each instrumentation Function, two channels of Manual Reactor Trip in each logic Function, and two trains in each Automatic Trip Logic Function.

Four OPERABLE instrumentation channels in a two-out-of-four configuration are required when one RTS channel is also used as a control system input. This configuration accounts for the possibility of the shared channel failing in such a manner that it creates a transient that requires RTS action. In this case, the RTS will still provide protection, even with random failure of one of the other three protection channels.

Three OPERABLE instrumentation channels in a two-out-of-three configuration are generally required when there is no potential for control system and protection system interaction that could simultaneously create a need for RTS trip and disable one RTS channel. The two-out-of-three and two-out-of-four configurations allow one channel to be tripped during maintenance or testing without causing a reactor trip. Specific exceptions to the above general philosophy exist and are discussed below.

Reactor Trip System Functions The safety analyses and OPERABILITY requirements applicable to each RTS Function are discussed below:

1.

Manual Reactor Trip The Manual Reactor Trip ensures that the control room operator can initiate a reactor trip at any time by using either of two reactor trip switches in the control room. A Manual Reactor Trip accomplishes the same results as any one of the automatic trip Functions. It is used by the reactor operator to shut down the reactor whenever any parameter is rapidly trending toward its Trip Setpoint. The manual actuating devices are independent of the automatic trip circuitry, and are not subject to failures which make the automatic circuitry inoperable.

The LCO requires two Manual Reactor Trip channels to be OPERABLE. Each channel is controlled by a manual reactor trip switch. Each channel activates the reactor trip breaker in both trains.

Two independent channels are required to be OPERABLE so that no single random failure will disable the Manual Reactor Trip Function.

Remove strikeouts shown in original LAR (ML23320A028, ML23320A029) from these sentences.

6 BASES RTS Instrumentation B 3.3.1 SURVEILLANCE REQUIREMENTS (continued) are declared inoperable. This Surveillance is performed to verify the f(Lll) input to the overtemperature 6 T Function.

A Note modifies SR 3.3.1.6. The Note states that this Surveillance is required only if reactor power is > 75% RTP and that 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed for performing the first surveillance after reaching 75% RTP.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.7 SR 3.3.1. 7 is the performance of a COT.

A COT is performed on each required channel to ensure the entire channel will perform the intended Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at. least once per refueling interval with applicable extensions.

Setpoints must be conservative with respect to the Allowable Values specified in Table 3.3.1-1.

The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology.

The "as-found" and "as-left" values must also be recorded and reviewed for consistency with the assumptions of Reference +.

SR 3.3.1.7 is modified by a Note that provides a 4 ~

s delay in the requirement to perform this Surveillance for source range instrumentation when entering MODE 3 from MODE 2. This Note allows a normal shutdown to proceed without a delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1.7 is no longer required to be performed. If the unit is to be in MODE 3 with the RTBs closed for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months this Surveillance must be performed prior to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

Turkey Point Unit 3 and Unit 4 B 3.3.1-42 Revision No. O

RTS Instrumentation B 3.3.1 Turkey Point Unit 3 and Unit 4 B 3.3.1-43 Revision No. 0 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.7 is modified by Notes as identified in Table 3.3.1-1. Note (b) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the channels will be evaluated under the plant Corrective Action Program.

Entry into the Corrective Action Program will ensure required review and documentation of the condition. Notes (c), (f), and (g) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable.

The Note (c) also requires that the nominal Trip Setpoint and the methodologies for calculating the as-left and the as-found tolerances be specified in Reference 2.

SR 3.3.1.8 SR 3.3.1.8 is the performance of a COT as described in SR 3.3.1.7, except it is modified by a Note that this test shall include verification that the P-6 and P-10 interlocks are in their required state for the existing unit condition. This verification can be performed by observation of the permissive annunciator window. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The test should also include verification of the High Flux at Shutdown Alarm Setpoint of 1/2 decade above the existing count rate. The Frequency is modified by a Note that allows this surveillance to be satisfied if it has been performed within the Remove strikeouts shown in original LAR (ML23320A028, ML23320A029) from this sentence.

After

RTS Instrumentation B 3.3.1 Turkey Point Unit 3 and Unit 4 B 3.3.1-44 Revision No. 0 BASES SURVEILLANCE REQUIREMENTS (continued)

Frequency specified in the Surveillance Frequency Control Program. The Frequency of "prior to startup" ensures this surveillance is performed prior to critical operations and applies to the source, intermediate and power range low instrument channels.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.8 is modified by Notes as identified in Table 3.3.1-1. Note (b) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. Notes (c), (f),

and (g) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained.

If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable.

The Note (c) also requires that the nominal Trip Setpoint and the methodologies for calculating the as-left and the as-found tolerances be specified in Reference 2.

SR 3.3.1.9 SR 3.3.1.9 is the performance of a CHANNEL CALIBRATION. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP.

The CHANNEL CALIBRATION for the source range and intermediate range neutron detectors consists of obtaining the detector plateau or Remove strikeouts shown in original LAR (ML23320A028, ML23320A029) from this sentence.

After l ------------

RTS Instrumentation B 3.3.1 Turkey Point Unit 3 and Unit 4 B 3.3.1-45 Revision No. 0 BASES SURVEILLANCE REQUIREMENTS (continued) preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.9 is modified by Notes as identified in Table 3.3.1-1. Note (b) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. Notes (c), (f),

and (g) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained.

If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable.

The Note (c) also requires that the nominal Trip Setpoint and the methodologies for calculating the as-left and the as-found tolerances be specified in Reference 2.

SR 3.3.1.10 SR 3.3.1.10 is the performance of a CHANNEL CALIBRATION. This SR is modified by a Note stating that this test shall include verification of the RCS resistance temperature detector (RTD) bypass loop flow rate.

Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

Remove strikeouts shown in original LAR (ML23320A028, ML23320A029) from this sentence.

After

RTS Instrumentation B 3.3.1 Turkey Point Unit 3 and Unit 4 B 3.3.1-46 Revision No. 0 BASES SURVEILLANCE REQUIREMENTS (continued)

This test will verify the rate lag compensation for flow from the core to the RTDs.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.10 is modified by Notes as identified in Table 3.3.1-1. Note (b) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. Notes (c), (f),

and (g) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained.

If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable.

The Note (c) also requires that the nominal Trip Setpoint and the methodologies for calculating the as-left and the as-found tolerances be specified in Reference 2.

SR 3.3.1.11 SR 3.3.1.11 is the performance of a COT of RTS interlocks. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Remove strikeouts shown in original LAR (ML23320A028, ML23320A029) from this sentence.

After

WCAP-18888-P, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 and 4 -

24-Month Fuel Cycle", January 2024.

BASES REFERENCES RTS Instrumentation B 3.3.1

1.

Regulatory Guide 1.105, Revision 3, "Setpoints for Safety Related Instrumentation."

2.

UFSAR, Chapter 7.

3.

UFSAR, Chapter 14.

4.

I EEE-279-1971.

5.

10 CFR 50.49.

6.

WGAP 12746, Re*tision 0, "\\/Vestinghouse Smpoint Methodology for Proteotion Systems Turkey Point Units 6 anel 4 Thermal Up rate Pfojeot," Noyember 1990-.

7-:

\\'VCAP 17070 P, Revision 1, "V\\lestinghouse Setpoint Methodology for Protection Systems Turl~ey Point Units 3 and 4, (Power Uprate to 2644 MINt Gore Pov,*er),11 dune 2011.

Turkey Point Unit 3 and Unit 4 B 3.3.1-48 Revision No. 0

WCAP-18888-P, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 and 4 Month Fuel Cycle" BASES Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.

3.2 BACKGROUND

(continued) the last test or calibration is verified to be within predefined limits and appropriate actions are taken if the change is outside these limits. The accep erived fr m the setpoint calculation based on the setpoint methodology described, \\OJCAP 12745 "WestiRghouse Setpoint Methodology for Protection Systems T1:1rl~ey Point Units 3 and 4,"

(Refs. 7 and 12) or '.ICAP 17070, "1/1/estinghouse Setpoint Methodology for Protestion Systems Turkey Point Units a and 4," (Ref. 11) as aJ:lplieaele.

If the trip setting exceeds the Allowable Value the channel is inoperable.

If the change in the trip settings exceeds the predefined limits but the setting is conservative with respect to the Allowable Value, and during the surveillance the instrument channel is functioning as expected and can be reset to within the setting tolerance of the Trip Setpoint, then the channel may be returned to service, and the condition entered into the corrective action program for further evaluation. However, if during the surveillance the change in the trip setting exceeds the predefined limits and it cannot be determined that the instrument channel is functioning as required, then the instrument is declared inoperable. Thus, verifying the trip setting is within the acceptance criteria band during test or calibration is part of the determination that an instrument is functioning as required.

Therefore, the channel would still be OPERABLE since it would have performed its safety function and the only corrective action required would be to reset the channel within the established calibration tolerance around the Trip Setpoint to account for further drift during the next surveillance interval.

During Anticipated Operational Occurrences (AOOs), which are those events expected to occur one or more times during the unit life, the acceptable limits are:

1.

The Departure from Nucleate Boiling Ratio (DNBR) shall be maintained above the SL value to prevent departure from nucleate boiling (DNB),

2.

Fuel centerline melt shall not occur, and

3.

The RCS pressure SL of 2735 psig shall not be exceeded.

Operation within the SLs of Specification 2.0, "Safety Limits (Sls), also maintains the above values and assures that offsite dose will be within the 10 CFR 50.67 criteria during AOOs.

Turkey Point Unit 3 and Unit 4 8 3.3 2-2 Revision No. 0

18888-P BASES Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.

3.2 BACKGROUND

(continued)

Trip Setpoints when all sensor and processing time delays are taken into account. To allow for calibration tolerances, instrumentation uncertainties, instrument drift, and severe environment errors for those ESFAS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 6), the Alloi.*.iable Values specified in Table 3.3.2-1 in the accompanying LCO are conservative with respect to the analytical limits. A detailed description of the methodology used to calculate the Allowable Values and ESF~

Setpoints including their explicit uncertainties, is provided in ~

Westinghouse topical reports WCAP 12746 and WCAP 17070 (Ref&. +

6fl0 11) which incorporates all of the known uncertainties applicable to each channel. A summary description of and reference to the calibration tolerance methodology is provided in UFSAR Chapter 7.2 (Ref. 2). The magnitudes of these uncertainties are factored into the determination of each ESFAS Trip Setpoint and corresponding Allowable Value. The nominal ESFAS setpoint entered into the bistable is R'lore oonservetitJe than that specified by the Trip Setpoint. to aooount for measurement errors deteetable by the CHANNEL OPER/\\TIONl',L TEST (GOT). The Allowable Value serves as the Technical Specification OPERABILITY limit for the purpose of the COT.

Trip Setpoint The Trip Setpoint is the value at which the bistables are set and is the expected value to be achieved during calibration. The.'\\llowable 'ialue,s the LSSS and ensures the safety analysis limits are met during the surveillance interval selected when a channel is adjusted based on stated channel uncertainties. Any bistable is considered to be properly adjusted when the "as-left" Trip Setpoint value is within the calibration tolerance for CHANNEL CALIBRATION uncertainty allowance (i.e., +-rack calibration and comparator setting uncertainties).

Trip Setpoints, in conjunction with the use of calibration tolerances together with the requirements of the Allowable Value ensure that the consequences of Design Basis Accidents (DBAs) will be acceptable, providing the unit is operated from within the LCOs at the onset of the OBA and the equipment functions as designed.

Note that the Allowable Values listed in Table 3.3.2-1 are the least conservative value of the as-found setpoint that a channel can have during a periodic CHANNEL CALIBRATION, COT, or a TADOT.

Each channel can be tested on line to verify that the signal processing equipment and setpoint accuracy is within the specified allowance requirements of Reference 3. Once a designated channel is taken out of service for testing, a simulated signal is injected in place of the field instrument signal. The process equipment for the channel in test is then tested, verified, and calibrated. SRs for the channels are specified in the SR section.

Turkey Point Unit 3 and Unit 4 B 3.3.2-5 Revision No. 0

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 Turkey Point Unit 3 and Unit 4 B 3.3.2-8 Revision No. 0 BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) evaluation will consist of resetting the channel setpoint to the Trip Setpoint (within the allowed tolerance) and evaluating the channel response. If the channel is functioning as required and expected to pass the next surveillance, then the channel can be restored to service at the completion of the surveillance.

A trip setpoint may be set more conservative than the Trip Setpoint as necessary in response to plant conditions. However, in this case, the OPERABILITY of this instrument must be verified based on the field setting and not the Trip Setpoint. Failure of any instrument renders the affected channel(s) inoperable and reduces the reliability of the affected Functions.

The LCO generally requires OPERABILITY of four or three channels in each instrumentation function and two channels in each logic and manual initiation function. The two-out-of-three and the two-out-of-four configurations allow one channel to be tripped during maintenance or testing without causing an ESFAS initiation. Two logic or manual initiation channels are required to ensure no single random failure disables the ESFAS.

The required channels of ESFAS instrumentation provide unit protection in the event of any of the analyzed accidents. ESFAS protection functions are as follows:

1.

Safety Injection Safety Injection (SI) provides two primary functions:

1.

Primary side water addition to ensure maintenance or recovery of reactor vessel water level (coverage of the active fuel for heat removal, clad integrity, and for limiting peak clad temperature to

< 2200°F), and

2.

Boration to ensure recovery and maintenance of SDM (keff < 1.0).

These functions are necessary to mitigate the effects of high energy line breaks (HELBs) both inside and outside of containment. The SI signal is also used to initiate other Functions such as:

x Phase A Isolation, x

Containment Ventilation Isolation, x

Reactor Trip, Remove strikeouts shown in original LAR (ML23320A028, ML23320A029) from these sentences.

and for meeting the 10 CFR 50.46 acceptance criteria (Ref. 12 and Ref. 13)

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 Turkey Point Unit 3 and Unit 4 B 3.3.2-36 Revision No. 0 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.2.3 is modified by Notes as identified in Table 3.3.2-1. Note (g) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. Notes (b),

(c), and (h) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained.

If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable.

Note (h) also requires that the nominal Trip Setpoint and the methodologies for calculating the as-left and the as-found tolerances be in UFSAR Section 7.2.

The SR is modified by a Note stating that testing of the alarm function for Functional Units 1.d, 1.e, 1.f, 1.g, 4.d, and 4.e, not required when alarm locked in.

SR 3.3.2.4 SR 3.3.2.4 is the performance of a TADOT. This test is a check of the Bus Stripping Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

Remove strikeouts shown in original LAR (ML23320A028, ML23320A029) from this sentence.

After

~

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 Turkey Point Unit 3 and Unit 4 B 3.3.2-38 Revision No. 0 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable.

SR 3.3.2.6 is modified by Notes as identified in Table 3.3.2-1. Note (g) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. Notes (b),

(c), and (h) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained.

If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable.

Note (h) also requires that the nominal Trip Setpoint and the methodologies for calculating the as-left and the as-found tolerances be in UFSAR Section 7.2.

REFERENCES

1.

Regulatory Guide 1.105, "Setpoint for Safety Related Instrumentation," Revision 3.

2.

UFSAR, Chapter 6.

3.

UFSAR, Chapter 7.

4.

UFSAR, Chapter 14.

5.

IEEE-279-1971.

6.

10 CFR 50.49.

Remove strikeouts shown in original LAR (ML23320A028, ML23320A029) from this sentence.

After

BASES Engineered Safety Feature Actuation System (ESFAS) Instrumentation B3.

3.2 REFERENCES

(continued)

!Deleted. I WCAP-18888-P, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 and 4 Month Fuel Cycle", January 2024.

7.

WCAP 12746, WestiAgho1:1se Set!'i)eiAt Metheaelegy fer PreteetieA SysleFA& Turkey PeiAt UAi~s a aAa 4."

8.

NRC Generic Letter 89-19, September 1989.

9.

WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

11. WG-Af' 17070 P, Rev~ttAgl:leuse Setpaint MctRosaleo,y fer ProtesUen Systems TuFl~ey Paint UAits a and 4, (Power Upr:ate to 2644 M\\A!t GoFe Pawe11~

12. 10 CFR 50.46.

13. WCAP-18546-P-A, March 2023.

Turkey Point Unit 3 and Unit 4 B 3.3.2-39 Revision No. 0

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 ENCLOSURE 3 WCAP-18888-NP, Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 24 Month Fuel Cycle, February 2024 (NON-PROPRIETARY)

(141 pages follow)

Westinghouse Non-Proprietary Class 3 WCAP-18888-NP February 2024 Revision 0 Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 24 Month Fuel Cycle

Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066

© 2024 Westinghouse Electric Company LLC All Rights Reserved WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP Revision 0 Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 24 Month Fuel Cycle Richard F. Karapandi*

Setpoints and Uncertainty Analysis February 2024 Reviewers:

Frank J. Koski*

Setpoints and Uncertainty Analysis Approved:

Steven R. Billman, Manager*

Setpoints and Uncertainty Analysis

Electronically approved records are authenticated in the electronic document management system.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 i

TABLE OF CONTENTS LIST OF TABLES............................................................................................................................ ii

1.0 INTRODUCTION

..................................................................................................................1 1.1 References / Standards............................................................................................2 2.0 COMBINATION OF UNCERTAINTY COMPONENTS........................................................3 2.1 Methodology.............................................................................................................3 2.2 Sensor Allowances...................................................................................................5 2.3 Rack Allowances......................................................................................................6 2.4 Process Allowances.................................................................................................7 2.5 References / Standards............................................................................................8 3.0 PROTECTION SYSTEM SETPOINT METHODOLOGY.....................................................9 3.1 Instrument Channel Uncertainty Calculations..........................................................9 3.2 Definitions for Protection System Setpoint Tolerances............................................9 3.3 References / Standards..........................................................................................18 4.0 APPLICATION OF THE SETPOINT METHODOLOGY...................................................132 4.1 Uncertainty Calculation Basic Assumptions / Premises.......................................132 4.2 Process Rack Operability Determination Program and Criteria...........................133 4.3 Application to the Plant Technical Specifications.................................................134 4.4 References / Standards........................................................................................136

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 ii LIST OF TABLES*

REACTOR TRIP SYSTEM / ENGINEERED SAFETY FEATURES ACTUATION SYSTEM /

CONTAINMENT VENTILATION ISOLATION CHANNEL ERROR ALLOWANCES Table 3-1 Power Range Neutron Flux - High....................................................................... 19 Table 3-2 Power Range Neutron Flux - Low........................................................................ 22 Table 3-3 Intermediate Range Neutron Flux......................................................................... 25 Table 3-4 Source Range Neutron Flux.................................................................................. 28 Table 3-5 Overtemperature T (Rosemount 3154NA6 Transmitters for Pressurizer Pressure)........................................................................................... 31 Table 3-5A Overtemperature T Calculations - Gains............................................................. 36 Table 3-6 Overpower T....................................................................................................... 38 Table 3-6A Overpower T Calculations - Gains...................................................................... 41 Table 3-7 Pressurizer Pressure - Low (Rosemount 3154NA6).............................................. 42 Table 3-8 Pressurizer Pressure - High (Rosemount 3154NA6)............................................. 45 Table 3-9 Pressurizer Water Level - High (Rosemount 3154ND3)........................................ 48 Table 3-10A Reactor Coolant Flow - Low, Single / Two Loops (Rosemount 1153HD5)............. 51 Table 3-10B Reactor Coolant Flow - Low, Single / Two Loops (Rosemount 3154ND3)............. 54 Table 3-11 Steam Generator Water Level - Low, Low-Low, Auxillary Feedwater (Rosemount 3154ND2)......................................................................................... 57 Table 3-12A Steam Flow / Feedwater Flow Mismatch (Rosemount 1153DD6 - Steam Flow, Rosemount 1153GB9 - Steam Pressure, Rosemount 1153DB5 - Feed Flow)...... 63 Table 3-12B Steam Flow / Feedwater Flow Mismatch (Rosemount 3154ND4 - Steam Flow, Rosemount 3154NG5 - Steam Pressure, Rosemount 3154ND3 - Feed Flow)..... 67 Table 3-13 Undervoltage 4.16 KV Buses A and B................................................................... 71 Table 3-14 Underfrequency RCPs Breakers Open................................................................. 74 Table 3-15 Turbine Trip - Emergency Trip Header Pressure................................................... 77 Table 3-16 Containment Pressure - High, Safety Injection (SI)............................................... 80 Table 3-17 Pressurizer Pressure - Low, SI (Rosemount 3154NA6)........................................ 83 Table 3-18A High Differential Pressure Between Steam Line Header and any Steam Generator, SI (Rosemount 1153GB9 / 1153GB9)................................................. 86 Table 3-18B High Differential Pressure Between Steam Line Header and any Steam Generator, SI (Rosemount 1153GB9 / 3154NG5)................................................. 89

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 iii LIST OF TABLES (continued)

Table 3-18C High Differential Pressure Between Steam Line Header and any Steam Generator, SI (Rosemount 3154NG5 / 3154NG5)................................................. 92 Table 3-19A Steam Line Flow - High, SI, Steamline Isolation (Rosemount 1153DD6 -

Steam Flow, Rosemount 1153GB8 - Turbine First Stage Pressure)..................... 95 Table 3-19B Steam Line Flow - High, SI, Steamline Isolation (Rosemount 3154ND4 -

Steam Flow, Rosemount 3154NG5 - Turbine First Stage Pressure)..................... 99 Table 3-20 Tavg - Low, SI, Steam Line Isolation................................................................... 103 Table 3-21A Steam Generator Pressure - Low, SI, Steam Line Isolation, Outside Containment Steam Break (Rosemount 1153GB9)................................ 106 Table 3-21B Steam Generator Pressure - Low, SI, Steam Line Isolation, Outside Containment Steam Break (Rosemount 3154NG5)............................... 109 Table 3-22A Steam Generator Pressure - Low, SI, Steam Line Isolation, Inside Containment Steam Break (Rosemount 1153GB9).................................. 112 Table 3-22B Steam Generator Pressure - Low, SI, Steam Line Isolation, Inside Containment Steam Break (Rosemount 3154NG5).................................. 115 Table 3-23 Containment Pressure - High-High, Containment Spray, Containment Isolation (Phase B)........................................................................ 118 Table 3-24 Steam Generator Water Level - High-High, Feedwater Isolation (Rosemount 3154ND2)....................................................................................... 121 Table 3-25 Containment Radiation - Gaseous...................................................................... 124 Table 3-26 Containment Radiation - Particulate.................................................................... 127 Table 3-27 P Measurements Expressed in Flow Units........................................................ 130

Due to multiple transmitter configurations, there is no summary table. That information can be found in Tables 3-1 through 3-26.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 1

1.0 INTRODUCTION

This report has been prepared to replace the following four WCAPS:

1.

WCAP-12745, Revision 0, Westinghouse Setpoint Methodology for Protection Systems -

Turkey Point Units 3 & 4, November 1990.

2.

WCAP-12745, Revision 1, Westinghouse Setpoint Methodology for Protection Systems, Turkey Point Units 3 and 4, Thermal Up-rate Project, 3.

WCAP-17070-P, Revision 3, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 (Power Uprate to 2644 MWt - Core Power), January 2021.

4.

WCAP-17283-P, Revision 2, Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 (Consolidation of WCAP-12745, Revisions 0 and 1 with WCAP-17070-P Revision 3), September 2021.

In Generic Letter 91-04(1), the NRC has noted that uncertainty calculations for 24-month fuel cycles should be performed in a manner which results in values at a high probability and a high confidence level. The implication of this is that a statistically rigorous calculation is required. To address the requirements for a definitive basis for drift, explicit calculations must be made to determine appropriate values for the transmitters and process racks.

This document is divided into four sections. Section 2.0 identifies the general algorithm used as a base to determine the overall instrument uncertainty for an RTS/ESFAS trip function. This approach is defined in a Westinghouse paper presented at an Instrument Society of America/Electric Power Research Institute (ISA/EPRI) conference in June, 1992(2). This approach is consistent with American National Standards Institute (ANSI), ANSI/ISA-67.04.01-2006(3). The basic uncertainty algorithm is the Square-Root-Sum-of-the-Squares (SRSS) of the applicable uncertainty terms, which is endorsed by the ISA standard. All appropriate and applicable uncertainties, as defined by a review of the plant baseline design input documentation, have been included in each RTS/ESFAS trip function uncertainty calculation. ISA-RP67.04.02-2000(4) was utilized as a general guideline, but each uncertainty and its treatment is based on Westinghouse methods which are consistent or conservative with respect to this document. NRC Regulatory Guide 1.105 (Revision 3(5)) endorses the 1994 version of ISA S67.04, Part I. Westinghouse has evaluated this NRC document and has determined that the RTS/ESFAS trip function uncertainty calculations contained in this report are consistent with the guidance contained in Revision 3(5). The total channel uncertainty (Channel Statistical Allowance or CSA) represents a 95/95 value as requested in Regulatory Guide 1.105(5).

Section 3.0 of this report provides a list of the defined terms and associated acronyms used in the RTS/ESFAS trip function uncertainty calculations. Appropriate references to industry standards have been provided where applicable.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 2

Included in this section are detailed descriptions of the uncertainty terms and values for each RTS/ESFAS trip function uncertainty calculation performed by Westinghouse.

Provided on each table is the function specific uncertainty algorithm which notes the appropriate combination of instrument uncertainties to determine the CSA. Tables 3-1 through 3-26 are provided which includes a listing of the Safety Analysis Limit (SAL), the Nominal Trip Setpoint (NTS), the Total Allowance (the difference between the SAL and NTS, in % span), margin, and the Allowable Value (AV). In all cases, it was determined that positive margin exists between the SAL and the NTS after accounting for the channel instrument uncertainties.

Section 4.0 provides a description of the methodology utilized in the determination of Turkey Point Units 3 and 4 Technical Specifications with regards to an explanation of the relationship between a trip setpoint and the allowable value.

1.1 References / Standards 1.

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

2.

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

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

3.

ANSI/ISA-67.04.01-2006, "Setpoints for Nuclear Safety-Related Instrumentation," May 2006.

4.

ISA-RP67.04.02-2000, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation," January 2000.

5.

Regulatory Guide 1.105, Revision 3, "Setpoints for Safety-Related Instrumentation," 1999.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 3

2.0 COMBINATION OF UNCERTAINTY COMPONENTS This section describes the Westinghouse setpoint methodology for the combination of the uncertainty components utilized for Turkey Point Units 3 and 4. The methodology used in the determination of the overall CSA, for the functions listed in this report, is in Section 2.1 below.

All appropriate and applicable uncertainties, as defined by a review of Turkey Point Units 3 and 4 baseline design input documentation have been included in each RTS/ESFAS trip function CSA calculation.

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

The basic methodology used is the SRSS technique. This technique, or others of a similar nature, has been used in WCAP 10395 (1) and WCAP 8567 (2). WCAP 8567 is approved by the NRC noting acceptability of statistical techniques for the application requested. Also, various ANSI, American Nuclear Society (ANS), and ISA standards approve the use of probabilistic and statistical techniques in determining safety related setpoints (3,4). The basic methodology used in this report is essentially the same as that identified in a Westinghouse paper presented at an ISA/EPRI conference in June, 1992(5). Differences between the algorithm presented in this paper and the equations presented in Tables 3-1 through 3-26 are due to Turkey Point Units 3 and 4 specific characteristics in design and should not be construed as differences in approach.

The generalized relationship between the uncertainty components and the calculated uncertainty for a channel is noted in Eq. 2.1:

CSA =

PMA+ PEA+ SRA+ (SMTE + SD)+ (SMTE + SCA)+

SPE+ STE+ (RMTE + RD)+ (RMTE + RCA)+

RTE

+EA + Bias Eq. 2.1

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 4

Where, CSA

=

Channel Statistical Allowance PMA

=

Process Measurement Accuracy PEA

=

Primary Element Accuracy SRA

=

Sensor Reference Accuracy SCA

=

Sensor Calibration Accuracy SMTE =

Sensor Measurement and Test Equipment Accuracy SPE

=

Sensor Pressure Effects STE

=

Sensor Temperature Effects SD

=

Sensor Drift RCA

=

Rack Calibration Accuracy RMTE =

Rack Measurement and Test Equipment Accuracy RTE

=

Rack Temperature Effects RD

=

Rack Drift EA

=

Environmental Allowance BIAS =

One directional, known magnitude allowance Each of the above terms is defined in Section 3.2, Definitions for Protection System Setpoint Tolerances.

Eq. 2.1 is based on the following: 1) The sensor and rack measurement and test equipment uncertainties are treated as dependent parameters with their respective drift and calibration accuracy allowances. 2) While the environmental allowances are not considered statistically dependent with all other parameters, the equipment qualification testing generally results in large magnitude, non-random terms that are conservatively treated as limits of error which are added to the statistical summation. Westinghouse generally considers a term to be a limit of error if the term is a bias with an unknown sign. The term is added to the SRSS in the direction of conservatism. 3) Bias terms are one directional with known magnitudes (which may result from several sources, e.g., drift or calibration data evaluations) and are also added to the statistical summation. 4) The calibration terms are treated in the same radical with the other terms based on an assumption of trending, i.e., drift and calibration data are evaluated on a periodic and timely basis. This evaluation should confirm that the distribution function characteristics assumed as part of the treatment of the terms are still applicable. 5) Turkey Point Units 3 and 4 will monitor the "as left" and "as found" data for the sensors and process racks. This process provides performance information that results in a net reduction of the CSA magnitude (over that which would be determined if data review were not performed).

Consistent with the request of Regulatory Guide 1.105(6), the CSA value from Eq. 2.1 has been determined at a 95 % probability and at a 95 % confidence level (95/95).

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 5

2.2 Sensor Allowances Seven parameters are considered to be sensor allowances: SRA, SCA, SMTE, SD, STE, SPE and EA. Three of these parameters are considered to be independent, two-sided, unverified (by plant calibration or drift determination processes), vendor supplied terms (SRA, STE and SPE). Based on vendor supplied data, typically product data sheets and qualification reports, these parameters are treated as 95/95 values unless specified otherwise by the vendor. Three of the remaining parameters are considered dependent with at least one other term, are two-sided, and are the result of the plant calibration and drift determination process (SCA, SMTE and SD).

The EA term is associated with the sensor exposure to adverse environmental conditions (elevated temperature and radiation) due to mass and energy loss from a break in the primary or secondary side piping, or adverse effects due to seismic events. Where appropriate, e.g.,

steamline break, only the elevated temperature term may be used for this uncertainty. The EA term magnitudes are conservatively treated as limits of error.

SRA is the manufacturer's reference accuracy that is achievable by the device. This term is introduced to address repeatability and hysteresis effects when performing only a single pass calibration, i.e., one up and one down(5,7). STE and SPE are considered to be independent due to the manner in which the instrumentation is checked; i.e., the instrumentation is calibrated and drift determined under conditions in which pressure and temperature are assumed constant. For example, assume a sensor is placed in some position in the containment during a refueling outage. After placement, an instrument technician calibrates the sensor at ambient pressure and temperature conditions. Sometime later with the plant shutdown, an instrument technician checks for sensor drift using the same technique as was previously used for calibrating the sensor. The conditions under which this drift determination is made are again ambient pressure and temperature. The temperature and pressure should be essentially the same at both measurements. Thus, they should have no significant impact on the drift determination and are, therefore, independent of the drift allowance.

SCA and SD are considered to be dependent with SMTE due to the manner in which the instrumentation is evaluated. A transmitter is calibrated by providing a known process input (measured with a high accuracy gauge) and evaluating the electrical output with a digital multimeter (DMM) or digital voltmeter (DVM). The gauge and DVM accuracies form the SMTE terms. The transmitter response is known, at best, to within the accuracy of the measured input and measured output. Thus the calibration accuracy (SCA) is functionally dependent with the measurement and test equipment (SMTE).

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 6

Since the gauge and DVM are independent of each other (they operate on two different physical principles), the two SMTE terms may be combined by SRSS prior to addition with the SCA term. Transmitter drift is determined using the same process used to perform a transmitter calibration. That is, a known process input (measured with a high accuracy gauge) is provided and the subsequent electrical output is measured with a DMM or DVM. In most cases the same measurement and test equipment is used for both calibration and drift determination. Thus the drift value (SD) is functionally dependent with the measurement and test equipment (SMTE) and is treated in the same manner as SMTE and SCA.

While the data is gathered in the same manner, SD is independent of SCA in that they are two different parameters. SCA is the difference between the "as left" value and the desired value.

SD is the difference between the "as found" value of the current calibration and the "as left" value of the previous calibration. It is assumed that a mechanistic cause and effect relationship between SCA and SD is not demonstrated and that any data evaluation will determine the distribution function characteristics for both SCA and SD and confirms that SD is random and independent of SCA.

2.3 Rack Allowances Four parameters are considered to be rack allowances: RCA, RMTE, RTE and RD. Rack Reference Accuracy (RRA) is the manufacturer's reference accuracy that is achievable by the process rack instrument string. This term is introduced to address repeatability and hysteresis effects when performing only a single pass calibration, i.e., one up and one down(5). Review of a sample of Turkey Point Units 3 and 4 specific calibration procedures has concluded that the calibration tolerance identified in the procedures is sufficient to encompass "as left" deviation and the hysteresis and repeatability effects without an additional allowance. Thus this term has been included in the RCA term in the uncertainty calculations. RTE is considered to be an independent, two-sided, unverified (by plant calibration or drift determination processes),

vendor supplied parameter. The process racks are located in an area with ambient temperature control, making consistency with the rack evaluation temperature easy to achieve.

Based on Westinghouse Eagle process rack data and Hagan rack data, this parameter is treated as a 95/95 value.

RCA and RD are considered to be two-sided terms dependent with RMTE. The functional dependence is due to the manner in which the process racks are evaluated. To calibrate or determine drift for the process rack portion of a channel, a known input (in the form of a voltage, current or resistance) is provided and the point at which the trip bistable changes state is measured. The input parameter is either measured by the use of a DMM or DVM (for a current or voltage signal) or is known to some degree of precision by use of precision equipment, e.g., a precision decade box for a resistance input.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 7

For simple channels, only a DMM or DVM is necessary to measure the input and the state change is noted by a light or similar device. For more complicated channels, multiple DVMs may be used or a DVM in conjunction with a decade box. The process rack response is known at best to within the accuracy of the measured input and indicated output. Thus the calibration accuracy (RCA) is functionally dependent with the measurement and test equipment (RMTE).

In those instances where multiple pieces of measurement and test equipment are utilized, the uncertainties are combined via SRSS when appropriate.

The RCA term represents the total calibration uncertainty for the channels which are calibrated as a single string. Drift for the process racks is determined using the same process used to perform the rack calibration and in most cases utilizes the same measurement and test equipment. Thus the drift value (RD) is also functionally dependent with the measurement and test equipment (RMTE) and is treated in the same manner as RMTE and RCA.

While the data is gathered in the same manner, RD is independent of RCA in that they are different parameters. RCA is the difference between the "as left" value and the desired value.

RD is the difference between the "as found" of the current calibration and the "as left" values of the previous calibration. The RD term represents the drift for all process rack modules in an instrument string, regardless of the channel complexity. For multiple instrument strings there may be multiple RD terms, e.g., Overtemperature T. It is assumed that a mechanistic cause and effect relationship between RCA and RD is not demonstrated and that any data evaluation will determine the distribution function characteristics for both RCA and RD and will confirm that RD is random and independent of RCA.

2.4 Process Allowances The PMA and PEA parameters are considered to be independent of both sensor and rack parameters. The PMA terms provide allowances for the non-instrument related effects; e.g.,

neutron flux, calorimetric power uncertainty assumptions and fluid density changes. There may be more than one independent PMA uncertainty allowance for a channel if warranted. The PEA term typically accounts for uncertainties due to metering devices, such as elbows, venturis, and orifice plates. In this report, this type of uncertainty is limited in application by Westinghouse to RCS Flow (Cold Leg Elbow Taps), high steam flow, and steam flow /

feedwater flow mismatch. In these applications, the PEA term has been determined to be independent of the sensors and process racks. It should be noted that treatment as an independent parameter does not preclude determination that a PMA or PEA term should be treated as a bias. If that is determined appropriate, Eq. 2.1 would be modified such that the affected term would be treated by arithmetic summation with appropriate determination and application of the sign of the uncertainty.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 8

2.5 References / Standards 1.

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

2.

Chelmer, H., Boman, L. H., and Sharp, D. R., "Improved Thermal Design Procedure,"WCAP-8567 (Proprietary), WCAP-8568 (Non-Proprietary), July 1975.

3.

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

4.

ANSI/ISA-67.04.01-2006, "Setpoints for Nuclear Safety-Related Instrumentation," May 2006.

5.

Tuley, C. R., Williams, T. P., "The Significance of Verifying the SAMA PMC 20.1-1973 Defined Reference Accuracy for the Westinghouse Setpoint Methodology,"

Instrumentation, Controls and Automation in the Power Industry, Vol. 35, Proceedings of the Thirty-Fifth Power Instrumentation Symposium (2nd Annual ISA/EPRI Joint Controls and Automation Conference), Kansas City, Mo., June 1992, p. 497.

6.

Regulatory Guide 1.105 Revision 3, Setpoints for Safety Related Instrumentation, 1999.

7.

ANSI/ISA-51.1-1979 (R1993), "Process Instrumentation Terminology," Reaffirmed May 26, 1995, p. 61.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 9

3.0 PROTECTION SYSTEM SETPOINT METHODOLOGY This section contains a list of defined terms used in the Turkey Point Units 3 and 4 RTS/ESFAS trip function uncertainty calculations. Also included in this section are detailed tables of the uncertainty terms and values for each calculation that Westinghouse performed. It was determined that in all cases sufficient margin exists between the nominal trip setpoint and the safety analysis limit after accounting for uncertainties.

3.1 Instrument Channel Uncertainty Calculations Tables 3-1through 3-26 provide individual parameter uncertainties and instrument channel uncertainty CSA calculations for the RTS and ESFAS functions identified in Tables 3.3.1-1 and 3.3.2-1 of the Turkey Point Units 3 & 4 Technical Specifications. Each table lists the Safety Analysis Limit, Nominal Trip Setpoint, and Allowable Value (in engineering units), and Channel Statistical Allowance, Margin, Total Allowance, As Left Tolerance, As Found Tolerance, and uncertainty terms (in % span).

Westinghouse reports TA, CSA and Margin values to one decimal place* using the technique of:

Rounding down values < 0.05% span,

Rounding up values 0.05% span, as defined in Reference 1.

Certain devices require higher resolution than one decimal place.

Parameters reported as:

N/A are not applicable, i.e., have no value for that channel,

0 are applicable but are included in other terms, e.g., normalized parameters,

0.0 are applicable with a value less than 0.05% span.

3.2 Definitions for Protection System Setpoint Tolerances For the channel uncertainty values used in this report, the following definitions are provided in alphabetical order:

As Found The condition in which a transmitter, process rack module, or process instrument loop is found after a period of operation. For example, after one cycle of operation, a Steam Generator Level transmitter's output at 50 % span was measured to be 12.05 mA.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 10 This would be the "as found" condition. For the process racks, the As Found Tolerance (AFT) is equal to the process rack As Left Tolerance (ALT), which is equal to the magnitude of the Rack Calibration Accuracy (RCA), i.e., AFT = ALT = RCA. The AFT is a two-sided parameter

(+/-) about the Nominal Trip Setpoint (NTS).

As Left The condition in which a transmitter, process rack module, or process instrument loop is left after calibration or bistable trip setpoint verification. This condition is typically better than the calibration accuracy for that piece of equipment. For example, the calibration point for a Steam Generator Level transmitter at 50 % span is 12.0 +/- 0.04 mA. A measured "as left" condition of 12.03 mA would satisfy this calibration tolerance. In this instance, if the calibration was stopped at this point (i.e., no additional efforts were made to decrease the deviation) the "as left" error would be + 0.03 mA or + 0.19 % span, assuming a 16 mA (4 to 20 mA) instrument span. For the process racks, the As Left Tolerance (ALT) is equal to the magnitude of the Rack Calibration Accuracy (RCA), i.e., ALT = RCA. The ALT is a two-sided parameter (+/-)

about the Nominal Trip Setpoint (NTS).

Channel The sensing and process equipment, i.e., transmitter to bistable, for one input to the voting logic of a protection function. Westinghouse designs protection functions with voting logic made up of multiple channels, e.g. 2 out of 3 Steam Generator Level - Low-Low channels for one steam generator must have their bistables in the tripped condition for a Reactor Trip to be initiated.

Channel Statistical Allowance (CSA)

The combination of the various channel uncertainties via SRSS and algebraic techniques. It includes instrument (sensor and process rack) uncertainties and non-instrument related effects (Process Measurement Accuracy), see Eq. 2.1. This parameter is compared with the Total Allowance for determination of instrument channel margin. The uncertainties and conservatism of the CSA algorithm (Eq. 2.1) result in a CSA magnitude that has been determined on a two-sided 95/95 basis.

Environmental Allowance (EA)

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

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 11

Temperature effects on a transmitter

Radiation effects on a transmitter

Seismic effects on a transmitter

Temperature effects on a level transmitter reference leg

Temperature effects on signal cable insulation

Seismic effects on process racks

Margin The calculated difference (in % instrument span) between the Total Allowance (TA) and the CSA.

Margin = TA - CSA Margin is defined to be a non-negative number i.e., Margin 0 % span.

Nominal Trip Setpoint (NTS)

A bistable trip setpoint in plant procedures. This value is the nominal value to which the bistable is set, as accurately as reasonably achievable. The NTS is based on engineering judgment (to arrive at a Margin 0 % span), or a historical value, that has been demonstrated over time to result in adequate operational margin.

Normalization The process of establishing a relationship, or link, between a process parameter and an instrument channel. This is in contrast with a calibration process. A calibration process is performed with independent known values, i.e., a bistable is calibrated to change state when a specific voltage is reached. This voltage corresponds to a process parameter magnitude with the relationship established through the scaling process. A normalization process typically involves an indirect measurement, e.g., determination of Steam Flow via the P drop across a flow restrictor. The flow coefficient for this device, (effectively an orifice which has not been calibrated in a laboratory setting), is not known. Therefore a mass balance between Feedwater Flow and Steam Flow must be made. The mass Feedwater Flow is known through measurement via the P across the venturi, Feedwater Pressure and Feedwater Temperature.

Presuming no mass losses prior to the measurement of the Steam Flow, the mass Steam Flow can be claimed to equal the mass Feedwater Flow. Measurement of the Steam Flow P and the Steam Pressure (to correct for density) can then be utilized to translate to a volumetric flow.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 12

Primary Element Accuracy (PEA)

Uncertainty due to the use of a metering device. In Westinghouse calculations, this parameter is limited to use on a venturi, orifice, elbow or potential transformer. Typically, this is a calculated or measured accuracy for the device.

Process Loop (Instrument Process Loop)

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

Process Measurement Accuracy (PMA)

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

Process Racks The analog modules downstream of the transmitter or sensing device, which condition a signal and act upon it prior to input to a voting logic system. For Hagan analog process systems, this includes all the equipment contained in the process equipment cabinets, e.g., conversion resistor, loop power supply, lead/lag, rate, lag functions, function generator, summator, control/protection isolator, and bistable. The go/no go signal generated by the bistable is the output of the last module in the analog process rack instrument loop and is the input to the voting logic.

Rack Calibration Accuracy (RCA)

Rack calibration accuracy is defined as the two-sided (+/-) calibration tolerance about the NTS of the process racks.

It is assumed that the individual modules in a loop are calibrated to a particular tolerance and that the process loop as a string is verified to be calibrated to a specific tolerance. The tolerance is typically less than the arithmetic sum or SRSS of the individual module tolerances.

This forces calibration of the process loop in such a manner as to exclude a systematic bias in the individual module calibrations, i.e., as left values for individual modules must be compensating in sign and magnitude when considered as an instrument string.

Review of a sample of Turkey Point Units 3 and 4 specific calibration procedures concluded that the calibration process and the identified RCA allowance is sufficient to encompass the as left deviation and the hysteresis and repeatability effects without an additional RRA allowance.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 13

Rack Drift (RD)

The change in input-output relationship over a period of time at reference conditions, e.g., at constant temperature. For example, assume that a Water Level channel at 50 % span (presuming a 1 to 5 V span) has an "as found" value of 3.01 V for the current calibration and an "as left" value of 2.99 V from the previous calculation. The magnitude of the drift would be

{(3.01 - 2.99)(100/4) = + 0.5 % span} in the positive direction. For Turkey Point Units 3 and 4 plant specific surveillance procedures, Florida Power and Light implements an additional requirement to compare the as found to the previous as left value to determine if drift allowance assumptions were exceeded since the last calibration activity.

Rack Measurement & Test Equipment Accuracy (RMTE)

The accuracy of the test equipment (typically a transmitter simulator, voltage or current power supply, and DVM) used to calibrate a process loop in the racks. When the magnitude of RMTE meets the requirements of SAMA Standard PMC 20.1-1973(9) or ANSI/ISA-51.1-1979 (R1993)(10) it is considered an integral part of RCA. Uncertainties due to M&TE that are 10 times more accurate than the device being calibrated are considered insignificant and are not included in the uncertainty calculations.

Rack Reference Accuracy (RRA)

Rack Reference Accuracy is the reference accuracy, as defined by SAMA Standard PMC 20.1-1973(1) for a process loop string. It is defined as the reference accuracy or accuracy rating that is achievable by the instrument string as specified in the manufacturer's specification sheets. Inherent in this definition is the verification of the following under a reference set of conditions;

1) conformity(2) or (6), 2) hysteresis(3) or (7) and 3) repeatability(4) or (8). An equivalent to the SAMA definition of reference accuracy is the ANSI/ISA-51.1-1979 (R1993)(5) term "accuracy rating,"

specifically as applied to Note 2 and Note 3.

Review of a sample of Turkey Point Units 3 and 4 specific calibration procedures and calibration assumptions concludes that the identified calibration allowance is sufficient to encompass the Rack Reference Accuracy without an additional allowance.

Rack Temperature Effects (RTE)

Change in input-output relationship for the process rack module string due to a change in the ambient environmental conditions (temperature, humidity), and voltage and frequency from the reference calibration conditions.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 14 It has been determined that temperature is the most significant, with the other parameters being second order effects. For process instrumentation, a typical value of [

]a,c is used for analog channel temperature effects which allows for a +/- 50 F ambient temperature deviation.

Range The upper and lower limits of the operating region for a device, e.g., for a Steamline Pressure transmitter, 0 to 1400 psig. This is not necessarily the calibrated span of the device, although quite often the two are close. For further information see ANSI/ISA-51.1-1979 (R1993)(10).

Safety Analysis Limit (SAL)

The parameter value in the UFSAR safety analysis or other plant operating limit at which a reactor trip or actuation function is assumed to be initiated.

Sensor Calibration Accuracy (SCA)

The two-sided (+/-) calibration accuracy for a sensor or transmitter as defined by the plant calibration procedures. For transmitters, this accuracy is typically [

]a,c. Utilizing Westinghouse recommendations for Resistance Thermal Detector (RTD) cross-calibration, this accuracy is typically [

]a,c for the Hot and Cold Leg RTDs.

Sensor Drift (SD)

The change in input-output relationship over a period of time at reference calibration conditions, e.g., at constant temperature. For example, assume a Water Level transmitter at 50 % level (presuming a 4 to 20 mA span) has an "as found" value of 12.05 mA from the current calibration and an "as left" value of 12.01 mA from the previous calibration. The magnitude of the drift would be {(12.05 - 12.01)(100/16) = + 0.25 % span} in the positive direction.

Sensor Measurement & Test Equipment Accuracy (SMTE)

The accuracy of the test equipment (typically a high accuracy local readout gauge and DVM) used to calibrate a sensor or transmitter in the field or in a calibration laboratory. When the magnitude of SMTE meets the requirements of ANSI/ISA-51.1-1979 (R1993)(10) it is considered an integral part of SCA. Uncertainties due to M&TE that are 10 times more accurate than the device being calibrated are considered insignificant and are not included in the uncertainty calculations.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 15

Sensor Pressure Effects (SPE)

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

Sensor Reference Accuracy (SRA)

The reference accuracy that is achievable by the device as specified in the manufacturer's specification sheets. This term is introduced into the uncertainty calculation to address repeatability effects when performing only a single pass calibration, i.e., one up and one down, or repeatability and hysteresis when performing a single pass calibration in only one direction.

Sensor Temperature Effects (STE)

The change in input-output relationship due to a change in the ambient environmental conditions (temperature, humidity), and voltage and frequency from the reference calibration conditions. It has been determined that temperature is the most significant, with the other parameters being second order effects. Note that the ambient temperature effects were evaluated using +/- 60 °F.

Span The region for which a device is calibrated and verified to be operable, e.g., for a Steamline Pressure transmitter, 1400 psi.

Square-Root-of-the-Sum-of-the-Squares (SRSS)

That is,

Total Allowance (TA)

The absolute value of the difference (in % instrument span) between the Safety Analysis Limit (SAL) and the Nominal Trip Setpoint (NTS).

)

(c

+

)

(b

+

)

(a

=

2 2

2

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 16 a,c Two examples of the calculation of TA are:

Power Range Neutron Flux - High a,c SAL NTS TA If the instrument span = 120% RTP, then a,c Steamline Pressure - Low (SI) a,c SAL NTS TA If the instrument span = 1400 psig, then a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 17 SAL (Safety Analysis Limit)

Margin (Total Allowance)

TA CSA (Channel Statistical Allowance)

+ As Left / As Found Tolerance RCA (0.5% span typical)

NTS (Nominal Trip Setpoint)

RCA (0.5% span typical)

- As Left / As Found Tolerance Figure 3-1 Westinghouse Setpoint Parameter Relationship Diagram

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 18 3.3 References / Standards 1.

Scientific Apparatus Makers Association Standard PMC 20.1-1973, "Process Measurement &

Control Terminology," p. 4.

2.

Ibid, p. 5.

3.

Ibid, p. 19.

4.

Ibid, p. 28.

5.

ANSI/ISA-51.1-1979 (R1993), "Process Instrumentation Terminology," Reaffirmed May 26, 1995, p. 12.

6.

Ibid, p. 16.

7.

Ibid, p. 36.

8.

Ibid, p. 49.

9.

Scientific Apparatus Makers Association Standard PMC 20.1-1973, "Process Measurement &

Control Terminology," p. 36.

10.

ANSI/ISA-51.1-1979 (R1993), "Process Instrumentation Terminology," Reaffirmed May 26, 1995, p. 61.

11.

ANSI/ISA-67.04.01-2006, "Setpoints for Nuclear Safety-Related Instrumentation," May 2006.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 19 Table 3-1 Power Range Neutron Flux - High Parameter Allowance*

a,c Process Measurement Accuracy (PMA) a,c Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift Bias Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (120% RTP)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 20 Table 3-1 (continued)

Power Range Neutron Flux - High Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 21 Table 3-1 (continued)

Power Range Neutron Flux - High Safety Analysis Limit (1)

=

115% RTP Nominal Trip Setpoint (2)

=

108% RTP Instrument Span

=

120% RTP Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

108.6% RTP Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1, Reactor Trip System Instrumentation of the plant Technical Specifications (TS).

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 22 Table 3-2 Power Range Neutron Flux - Low Parameter Allowance*

a,c Process Measurement Accuracy a,c Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift Bias Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (120% RTP)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 23 Table 3-2 (continued)

Power Range Neutron Flux - Low Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 24 Table 3-2 (continued)

Power Range Neutron Flux - Low Safety Analysis Limit (1)

=

35% RTP Nominal Trip Setpoint (2)

=

25% RTP Instrument Span

=

120% RTP Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

25.6% RTP Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 25 Table 3-3 Intermediate Range Neutron Flux Parameter Allowance*

a,c Process Measurement Accuracy (PMA) a,c Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (120% RTP)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 26 Table 3-3 (continued)

Intermediate Range Neutron Flux Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 27 Table 3-3 (continued)

Intermediate Range Neutron Flux Safety Analysis Limit (1)

=

N/A Nominal Trip Setpoint (2)

=

25% RTP Instrument Span

=

120% RTP Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

25.6% RTP Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 28 Table 3-4 Source Range Neutron Flux Parameter Allowance*

a,c Process Measurement Accuracy (PMA) a,c Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift (SD)

Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (1.0E+06 CPS)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 29 Table 3-4 (continued)

Source Range Neutron Flux Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 30 Table 3-4 (continued)

Source Range Neutron Flux Safety Analysis Limit (1)

=

N/A Nominal Trip Setpoint (2)

=

1.00E+05 CPS Instrument Span

=

1.00E+06 CPS Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

1.05E+05 CPS Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 31 Table 3-5 Overtemperature T Rosemount 3154NA6 Transmitters for Pressurizer Pressure Parameter Allowance*

a,c Process Measurement Accuracy (PMA) a,c Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE) a,c Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE) a,c Sensor Drift a,c Bias a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 32 Table 3-5 (continued)

Overtemperature T Rosemount 3154NA6 Transmitters for Pressurizer Pressure Parameter Allowance*

a,c Rack Calibration Accuracy (RCA) a,c Rack Measurement & Test Equipment Accuracy (RMTE) a,c Rack Temperature Effect (RTE) a,c Rack Drift (RD) a,c

In percent T span:

(Tavg - 100°F, Pressurizer Pressure - 1000 psig, T - 100°F = 159.4% RTP, I - 120% I, ERI - 150°F) a,c NH = # of hot leg RTDs = 2 NC = # of cold leg RTDs = 1

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 33 Table 3-5 (continued)

Overtemperature T Rosemount 3154NA6 Transmitters for Pressurizer Pressure Channel Statistical Allowance =

a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 34 Table 3-5 (continued)

Overtemperature T Rosemount 3154NA6 Transmitters for Pressurizer Pressure Channel Statistical Allowance =

a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 35 Table 3-5 (continued)

Overtemperature T Rosemount 3154NA6 Transmitters for Pressurizer Pressure Safety Analysis Limit (K1SAL)(1)

= 1.45 RTP Nominal Trip Setpoint (K1nom)(2)

= 1.31 RTP Instrument Span

= Tavg = 100°F

= Power = 159.4% Rated Thermal Power

= T span = 100°F

= I = +/- 60% I

= NIS = +/- 60% I Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(3)

= T = 0.5% T span

= Pressure = 0.2% T span

= I = 0.4% T span a,c Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-17 of the plant Technical Specifications.

3.

As noted in Table 3.3.1-18 of the plant Technical Specifications.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 36 Table 3-5A Overtemperature T Calculations - Gains The equation for Overtemperature T is:

I f

P' P

K T'

S 1

1 T

S 1

K K

T S

1 1

S 1

T 1

3 6

5 4

2 1

0 3

2 1

K1 (nominal)

K1 (max)

=

K2 K3 T

=

T span

=

T span_pwr =

I gain

=

1.310

[

] a,c 0.023 / °F 0.00116/psi 62.74 F smallest T allowance for uprate conditions 100 °F 159.4 % RTP 2.37 % RTP / % I PMA conversions a,c I1 (PMA)

=

I2 (PMA)

=

T (PMA)

=

Tavg (PMA)

=

Power Cal. (PMAPWR CAL) =

Pressurizer Pressure 3154 a,c Pressure (SCA)

=

Pressure (SRA)

=

Pressure (SMTE)

=

Pressure (STE)

=

Pressure (SD)

=

Pressure (Bias1)

=

Pressure (Bias2)

=

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 37 Table 3-5A (continued)

Overtemperature T Calculations - Gains Pressurizer Pressure Rack Terms Pressure (RCAP)

=

Pressure (RMTEP)

=

Pressure (RTEP)

=

Pressure (RDP)

=

ERI Rack Terms a,c ERI conversion

=

ERI (RCA)

=

ERI (RMTE)

=

ERI (RTE)

=

ERI (RD)

=

I Rack Terms a,c I conversion

=

I (RCA)

=

I (RMTE)

=

I (RTE)

=

I (RD)

=

NISI Rack Terms a,c NIS conversion

=

NIS (RCANIS)

=

NIS (RMTENIS)

=

NIS (RTENIS)

=

NIS (RDNIS)

=

Total Allowance = [

] a,c = 8.8 % T span a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 38 Table 3-6 Overpower T Parameter Allowance*

a,c Process Measurement Accuracy a,c Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE) a,c Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift a,c RTD Hysteresis Bias (HYS)**

Environmental Allowance (EA)**

a,c Rack Calibration Accuracy (RCA) a,c Rack Measurement & Test Equipment Accuracy (RMTE) a,c Rack Temperature Effect (RTE) a,c Rack Drift (RD) a,c

In percent T span: (Tavg - 100°F, T - 100°F = 159.4% RTP, I - 120% I, ERI - 150°F) a,c NH = # of hot leg RTDs = 2 NC = # of cold leg RTDs = 1

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 39 Table 3-6 (continued)

Overpower T Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 40 Table 3-6 (continued)

Overpower T Safety Analysis Limit (K1SAL)(1)

= 1.146 RTP Nominal Trip Setpoint (K1nom)(2)

= 1.09 RTP Instrument Span

= Tavg = 100°F

= Power = 159.4% Rated Thermal Power

= T span = 100°F

= I = +/- 60% I

= NIS = +/- 60% I Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(3)

= T = 0.5% T span a,c Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-19 of the plant Technical Specifications.

3.

As noted in Table 3.3.1-20 of the plant Technical Specifications.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 41 Table 3-6A Overpower T Calculations - Gains The equation for Overpower T is:

I f

T' S

1 1

T K

T S

1 1

S 1

S K

K T

S 1

1 S

1 T

2 6

6 6

7 7

5 4

0 3

2 1

K4 (nominal)

K4 (max)

=

K5

=

K6 T

1.09

[

] a,c 0.0/°F 0.0016/°F for T > T" and K6 = 0 for T T" 62.74 °F smallest T allowance for uprate conditions PMA Conversions a,c T (PMA)

=

Tavg (PMA) *

=

Power Cal. (PMAPWR CAL) =

ERI Rack Terms a,c ERI conversion

=

ERI (RCA)

=

ERI (RMTE)

=

ERI (RTE)

=

ERI (RD)

=

Total Allowance = [

] a,c = 3.5 % T span a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 42 Table 3-7 Pressurizer Pressure - Low Rosemount 3154NA6 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift (SD)

Bias a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (1000 psig)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 43 Table 3-7 (continued)

Pressurizer Pressure - Low Rosemount 3154NA6 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 44 Table 3-7 (continued)

Pressurizer Pressure - Low Rosemount 3154NA6 Safety Analysis Limit(1)

=

1790 PSIG Nominal Trip Setpoint (2)

=

1835 PSIG Instrument Span

=

1000 PSIG Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

1830 PSIG Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 45 Table 3-8 Pressurizer Pressure - High Rosemount 3154NA6 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift (SD)

Bias a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (1000 psig)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 46 Table 3-8 (continued)

Pressurizer Pressure - High Rosemount 3154NA6 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 47 Table 3-8 (continued)

Pressurizer Pressure - High Rosemount 3154NA6 Safety Analysis Limit (1)

=

2440 PSIG Nominal Trip Setpoint (2)

=

2385 PSIG Instrument Span

=

1000 PSIG Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

2390 PSIG Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 48 Table 3-9 Pressurizer Water Level - High Rosemount 3154ND3 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift (SD)

Bias a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (100% span)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 49 Table 3-9 (continued)

Pressurizer Water Level - High Rosemount 3154ND3 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 50 Table 3-9 (continued)

Pressurizer Water Level - High Rosemount 3154ND3 Safety Analysis Limit (1)

=

100.0% span Nominal Trip Setpoint (2)

=

92.0% span Instrument Span

=

100% span Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

92.2% span Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 51 Table 3-10A Reactor Coolant Flow - Low, Single / Two Loops Rosemount 1153HD5 Parameter Allowance*

a,c Process Measurement Accuracy (PMA) a,c Primary Element Accuracy (PEA) a,c Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE) a,c Sensor Pressure Effect (SPE) a,c Sensor Temperature Effect (STE) a,c Sensor Drift (SD) a,c Seismic Bias (Bias_2)

Rack Calibration Accuracy (RCA) a,c Rack Measurement & Test Equipment Accuracy (RMTE) a,c Rack Temperature Effect (RTE) a,c Rack Drift (RD) a,c

In % flow span (120% Thermal Design Flow). Percent P span converted to flow span via Equation 3-27.8, with Fmax = 120 % and FN = 90 %, therefore, gain = [

].a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 52 Table 3-10A (continued)

Reactor Coolant Flow - Low, Single / Two Loops Rosemount 1153HD5 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 53 Table 3-10A (continued)

Reactor Coolant Flow - Low, Single / Two Loops Rosemount 1153HD5 Safety Analysis Limit (1)

=

84.5% TDF Nominal Trip Setpoint (2)

=

90.0% TDF Instrument Span

=

120% TDF Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

89.6% TDF Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Flow Span.

4.

Reactor Coolant Flow may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the reactor coolant flow low function with reactor coolant flow provided by a Rosemount 1153HD5 transmitter. This configuration represents the bounding (worst case) CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 54 Table 3-10B Reactor Coolant Flow - Low, Single / Two Loops Rosemount 3154ND3 Parameter Allowance*

a,c Process Measurement Accuracy (PMA) a,c Primary Element Accuracy (PEA) a,c Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE) a,c Sensor Pressure Effect (SPE) a,c Sensor Temperature Effect (STE) a,c Sensor Drift (SD) a,c Seismic Bias (Bias_2)

Rack Calibration Accuracy (RCA) a,c Rack Measurement & Test Equipment Accuracy (RMTE) a,c Rack Temperature Effect (RTE) a,c Rack Drift (RD) a,c

In % flow span (120% Thermal Design Flow). Percent P span converted to flow span via Equation 3-27.8, with Fmax = 120 % and FN = 90 %, therefore, gain = [

].a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 55 Table 3-10B (continued)

Reactor Coolant Flow - Low, Single / Two Loops Rosemount 3154ND3 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 56 Table 3-10B (continued)

Reactor Coolant Flow - Low, Single / Two Loops Rosemount 3154ND3 Safety Analysis Limit (1)

=

84.5% TDF Nominal Trip Setpoint (2)

=

90.0% TDF Instrument Span

=

120% span Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

89.6% TDF Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Flow Span.

4.

Reactor Coolant Flow may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the reactor coolant flow low function with reactor coolant flow provided by a Rosemount 3154ND3 transmitter. This configuration represents the best case CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 57 Table 3-11 Steam Generator Water Level - Low, Low Low, Auxiliary Feedwater Rosemount 3154ND2 Parameter Allowance*

Process Measurement Accuracy (PMA)**

a,c a,c Primary Element Accuracy (PEA)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 58 Table 3-11 (continued)

Steam Generator Water Level - Low, Low Low, Auxiliary Feedwater Rosemount 3154ND2 Parameter Allowance*

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift (SD)

Bias**

a,c Environmental Allowance (EA)**

a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (100% RTP) a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 59 Table 3-11 (continued)

Steam Generator Water Level - Low, Low Low, Auxiliary Feedwater Rosemount 3154ND2 Loss of Normal Feedwater - Single Loop Channel Statistical Allowance =

a,c a,c Loss of Normal Feedwater - All Loops Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 60 Table 3-11 (continued)

Steam Generator Water Level - Low, Low Low, Auxiliary Feedwater Rosemount 3154ND2 Large Break Channel Statistical Allowance =

a,c

This equation can use either EA_2 or EA_3 since they are the same value.

a,c Small/intermediate Feedbreak Channel Statistical Allowance =

a,c

This equation can use either EA_2 or EA_3 since they are the same value.

a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 61 Table 3-11 (continued)

Steam Generator Water Level - Low, Low Low, Auxiliary Feedwater Rosemount 3154ND2 Small Steambreak LONF Channel Statistical Allowance =

a,c

This equation can use either EA_2 or EA_3 since they are the same value.

a,c Small Steambreak Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 62 Table 3-11 (continued)

Steam Generator Water Level - Low, Low Low, Auxiliary Feedwater Rosemount 3154ND2 Loss of Normal Feedwater (Single Loop and All Loops)

Safety Analysis Limit (1)

=

11.0% span Steam Generator Level - Low-Low Feedline Break Adverse Environments Safety Analysis Limit (1)

=

0% span Nominal Trip Setpoint (2)

=

16% span Instrument Span

=

100% span Total Allowance_LONF

=

a,c Total Allowance_FB

=

Loss of Normal Feedwater - Single Loop Channel Statistical Allowance

=

a,c Margin

=

Loss of Normal Feedwater - All Loop Channel Statistical Allowance

=

a,c Margin

=

Large Feedline Break Channel Statistical Allowance

=

a,c Margin

=

Small/intermediate Feedbreak Channel Statistical Allowance

=

a,c Margin

=

Small Steambreak LONF Channel Statistical Allowance

=

a,c Margin

=

Small Steambreak Channel Statistical Allowance

=

a,c Margin

=

Allowable Value(2)

=

15.5% span Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 and Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 63 Table 3-12A Steam Flow / Feedwater Flow Mismatch Rosemount 1153DD6 - Steam Flow, Rosemount 1153GB9 - Steam Pressure, Rosemount 1153DB5 - Feed Flow Parameter Allowance*

Process Measurement Accuracy (PMA) a,c

[

]a,c

[

]a,c

[

]a,c Primary Element Accuracy (PEA)

Steam Flow

[

]a,c Feed Flow

[

]a,c Sensor Calibration Accuracy (SCA)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Reference Accuracy (SRA)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Pressure Effects (SPE)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Temperature Effects (STE)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Drift (SD)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 64 Table 3-12A (continued)

Steam Flow / Feedwater Flow Mismatch Rosemount 1153DD6 - Steam Flow, Rosemount 1153GB9 - Steam Pressure, Rosemount 1153DB5 - Feed Flow Parameter Allowance*

Environmental Allowance (EA) a,c Bias Sensor Drift Bias (Bias1)

Seismic bias (Bias2)

Rack Calibration Accuracy (RCA)

Steam Flow Feed Flow Rack Measurement & Test Equipment Accuracy (RMTE)

Steam Flow Feed Flow Rack Temperature Effects (RTE)

Steam Flow Feed Flow Rack Drift (RD)

Steam Flow Feed Flow

In percent flow span (135.9 % Span). Values are converted to flow span via Equation 3-27.8 where Fmax = 135.9 %, FN (steam flow) = 100 %, and FN (feedwater flow) = 80 %; therefore, gain1 (steam flow) = [

]a,c and gain2 (feedwater flow) = [

].a,c The gain3 for steam pressure = [

].a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 65 Table 3-12A (continued)

Steam Flow / Feedwater Flow Mismatch Rosemount 1153DD6 - Steam Flow, Rosemount 1153GB9 - Steam Pressure, Rosemount 1153DB5 - Feed Flow Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 66 Table 3-12A (continued)

Steam Flow / Feedwater Flow Mismatch Rosemount 1153DD6 - Steam Flow, Rosemount 1153GB9 - Steam Pressure, Rosemount 1153DB5 - Feed Flow Safety Analysis Limit (1)

=

N/A Nominal Trip Setpoint (2)

=

20.0% below full steam flow Instrument Span

=

135.9% full steam flow Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

20.7% below full steam flow Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span 4.

Steam flow, steam pressure & feedwater flow may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the steam flow /

feedwater flow mismatch function with steam flow, steam pressure and feedwater flow provided by Rosemount 1153DD6, 1153GB9 & 1153DB5 transmitters, respectively. This configuration represents the bounding (worst case) CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 67 Table 3-12B Steam Flow / Feedwater Flow Mismatch Rosemount 3154ND4 - Steam Flow, Rosemount 3154NG5 - Steam Pressure, Rosemount 3154ND3 - Feed Flow Parameter Allowance*

Process Measurement Accuracy a,c

[

]a,c

[

]a,c

[

]a,c Primary Element Accuracy (PEA)

Steam Flow

[

]a,c Feed Flow

[

]a,c Sensor Calibration Accuracy (SCA)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Reference Accuracy (SRA)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Pressure Effects (SPE)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Temperature Effects (STE)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c Sensor Drift (SD)

Steam Flow

[

]a,c Feed Flow

[

]a,c Steam Pressure [

]a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 68 Table 3-12B (continued)

Steam Flow / Feedwater Flow Mismatch Rosemount 3154ND4 - Steam Flow, Rosemount 3154NG5 - Steam Pressure, Rosemount 3154ND3 - Feed Flow Parameter Allowance*

Environmental Allowance (EA) a,c Bias Sensor Drift Bias (Bias1)

Seismic bias (Bias2)

Rack Calibration Accuracy (RCA)

Steam Flow Feed Flow Rack Measurement & Test Equipment Accuracy (RMTE)

Steam Flow Feed Flow Rack Temperature Effects (RTE)

Steam Flow Feed Flow Rack Drift (RD)

Steam Flow Feed Flow

In percent flow span (135.9 % Span). Values are converted to flow span via Equation 3-27.8 where Fmax = 135.9 %, FN (steam flow) = 100 %, and FN (feedwater flow) = 80 %; therefore, gain1 (steam flow) = [

]a,c and gain2 (feedwater flow) = [

].a,c The gain3 for steam pressure = [

].a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 69 Table 3-12B (continued)

Steam Flow / Feedwater Flow Mismatch Rosemount 3154ND4 - Steam Flow, Rosemount 3154NG5 - Steam Pressure, Rosemount 3154ND3 - Feed Flow Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 70 Table 3-12B (continued)

Steam Flow / Feedwater Flow Mismatch Rosemount 3154ND4 - Steam Flow, Rosemount 3154NG5 - Steam Pressure, Rosemount 3154ND3 - Feed Flow Safety Analysis Limit (1)

=

N/A Nominal Trip Setpoint (2)

=

20.0% below full steam flow Instrument Span

=

135.9% full steam flow Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

20.7% below full steam flow Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam flow, steam pressure & feedwater flow may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the steam flow /

feedwater flow mismatch function with steam flow, steam pressure and feedwater flow provided by Rosemount 3154ND4, 3154NG5 & 3154ND3 transmitters, respectively. This configuration represents the best case CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 71 Table 3-13 Undervoltage 4.16 KV Buses A and B Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift

Values are in Volts. Adjustable Drop-Out Range is 30 VAC.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 72 Table 3-13 (continued)

Undervoltage 4.16 KV Buses A and B Channel Statistical Allowance =

Channel Statistical Allowance (CSA) calculated in Volts at the relay.

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 73 Table 3-13 (continued)

Undervoltage 4.16 KV Buses A and B Safety Analysis Limit (1)

=

N/A Nominal Trip Setpoint (2)

=

70% Bus Voltage

=

a,c Instrument Range

=

30 V Adjustable Drop-Out Range Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

69% Bus Voltage

=

a,c NTS Setpoint +/- As Found Tolerance (AFT)

=

NTS Setpoint +/- As Left Tolerance (ALT)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Not rounded to tenths due to resolution required.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 74 Table 3-14 Underfrequency RCPs Breakers Open Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift

Values in Hz. Span is 16.98 Hz.**

- Not rounded to tenths because resolution is required.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 75 Table 3-14 (continued)

Underfrequency RCPs Breakers Open Channel Statistical Allowance =

Channel Statistical Allowance (CSA) calculated in Hz a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 76 Table 3-14 (continued)

Underfrequency RCPs Breakers Open Safety Analysis Limit (1)

=

55.0 Hz Nominal Trip Setpoint (2)

=

56.1 Hz Instrument Range

=

16.98 Hz(3)

Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

56.08% Hz(3)

NTS Setpoint +/- As Found Tolerance (AFT)

=

a,c NTS Setpoint +/- As Left Tolerance (ALT)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Not rounded to tenths because resolution is required.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 77 Table 3-15 Turbine Trip - Emergency Trip Header Pressure Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift Bias Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

Rack Reference Accuracy (RRA)

In percent span (3300 psi)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 78 Table 3-15 (continued)

Turbine Trip - Emergency Trip Header Pressure Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 79 Table 3-15 (continued)

Turbine Trip - Emergency Trip Header Pressure Safety Analysis Limit (1)

=

N/A Nominal Trip Setpoint (2)

=

1000 psig Instrument Span

=

3300 psig Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

901psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.1-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 80 Table 3-16 Containment Pressure - High, SI Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Rack Drift Bias (RD_HBias)

Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (15 psi)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 81 Table 3-16 (continued)

Containment Pressure - High, SI Channel Statistical Allowance =

a,c a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 82 Table 3-16 (continued)

Containment Pressure - High, SI Safety Analysis Limit (1)

=

6 psig Nominal Trip Setpoint (2)

=

4 psig Instrument Span

=

15 psig Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

4.5 psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 83 Table 3-17 Pressurizer Pressure - Low, Safety Injection Rosemount 3154NG6 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift (SD)

Bias a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (1000 psig))

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 84 Table 3-17 (continued)

Pressurizer Pressure - Low, Safety Injection Rosemount 3154NG6 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 85 Table 3-17 (continued)

Pressurizer Pressure - Low, Safety Injection Rosemount 3154NG6 Safety Analysis Limit (1)

=

1600 PSIG Nominal Trip Setpoint (2)

=

1730 PSIG Instrument Span

=

1000 PSIG Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

1725 PSIG Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 86 Table 3-18A High Differential Pressure Between Steam Line Header and any Steam Generator, SI Rosemount 1153GB9 / 1153GB9 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effect (SPE) a,c Sensor Temperature Effect (STE) a,c Sensor Drift (SD) a,c Rack Calibration Accuracy (RCA) a,c Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE) a,c Rack Drift (RD) a,c

In percent span (1400 psig)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 87 Table 3-18A (continued)

High Differential Pressure Between Steam Line Header and any Steam Generator, SI Rosemount 1153GB9 / 1153GB9 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 88 Table 3-18A (continued)

High Differential Pressure Between Steam Line Header and any Steam Generator, SI Rosemount 1153GB9 / 1153GB9 Safety Analysis Limit (1)

=

165 psig Nominal Trip Setpoint (2)

=

100 psig Instrument Span

=

1400 psig Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

107 psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam line header pressure & steam generator pressure may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the high differential pressure between the steam line header and any steam generator, SI function with steam line header pressure and steam generator pressure provided by Rosemount 1153GB9 & 1153GB9 transmitters, respectively. This configuration represents the bounding (worst case) CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 89 Table 3-18B High Differential Pressure Between Steam Line Header and any Steam Generator, SI Rosemount 1153GB9 / 3154NG5 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effect (SPE) a,c Sensor Temperature Effect (STE) a,c Sensor Drift (SD) a,c Rack Calibration Accuracy (RCA) a,c Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE) a,c Rack Drift (RD) a,c

In percent span (1400 psig)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 90 Table 3-18B (continued)

High Differential Pressure Between Steam Line Header and any Steam Generator, SI Rosemount 1153GB9 / 3154NG5 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 91 Table 3-18B (continued)

High Differential Pressure Between Steam Line Header and any Steam Generator, SI Rosemount 1153GB9 / 3154NG5 Safety Analysis Limit (1)

=

165 psig Nominal Trip Setpoint (2)

=

100 psig Instrument Span

=

1400 psig Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

107 psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam line header pressure & steam generator pressure may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the high differential pressure between the steam line header and any steam generator, SI function with steam line header pressure and steam generator pressure provided by Rosemount 1153GB9 & 3154NG5 transmitters, respectively.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 92 Table 3-18C High Differential Pressure Between Steam Line Header and any Steam Generator, SI Rosemount 3154NG5 / 3154NG5 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effect (SPE) a,c Sensor Temperature Effect (STE) a,c Sensor Drift (SD) a,c Rack Calibration Accuracy (RCA) a,c Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE) a,c Rack Drift (RD) a,c

In percent span (1400 psig)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 93 Table 3-18C (continued)

High Differential Pressure Between Steam Line Header and any Steam Generator, SI Rosemount 3154NG5 / 3154NG5 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 94 Table 3-18C (continued)

High Differential Pressure Between Steam Line Header and any Steam Generator, SI Rosemount 3154NG5 / 3154NG5 Safety Analysis Limit (1)

=

165 psig Nominal Trip Setpoint (2)

=

100 psig Instrument Span

=

1400 psig Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

107 psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam line header pressure & steam generator pressure may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the high differential pressure between the steam line header and any steam generator, SI function with steam line header pressure and steam generator pressure provided by Rosemount 3154NG5 & 3154NG5 transmitters, respectively. This configuration represents the best case CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 95 Table 3-19A Steam Line Flow - High, SI, Steamline Isolation Rosemount 1153DD6 - Steam Flow, Rosemount 1153GB8 - Turbine First Stage Pressure Process Measurement Accuracy (PMA) a,c

[

]a,c

[

]a,c

[

]a,c

[

]a,c

[

]a,c

[

]a,c Primary Element Accuracy (PEA)

Steam Flow

[

]a,c Turbine Pressure

[

]a,c Sensor Calibration Accuracy (SCA)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Sensor Reference Accuracy (SRA)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Sensor Pressure Effects (SPE)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Sensor Temperature Effects (STE)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 96 Table 3-19A (continued)

High Steam Line Flow - SI, Steam Line Isolation Rosemount 1153DD6 - Steam Flow, Rosemount 1153GB8 - Turbine First Stage Pressure Parameter Allowance*

Sensor Drift (SD) a,c Steam Flow (100% TP)

[

]a,c Steam Flow (20% TP)

[

]a,c Turbine Pressure (100% TP) [

]a,c Turbine Pressure (20% TP) [

]a,c Environmental Allowances (EA)

Steam Flow Turbine Pressure Bias Sensor Drift Bias (Bias1)

Seismic bias (Bias2)

Rack Calibration Accuracy (RCA)

Steam Flow (100% TP)

[

]a,c Steam Flow (20% TP)

[

]a,c Turbine Pressure (100% TP) [

]a,c Turbine Pressure (20% TP) [

]a,c Rack Measurement & Test Equipment Accuracy (RMTE)

Steam Flow (100% TP)

[

]a,c Steam Flow (20% TP)

[

]a,c Turbine Pressure (100% TP) [

]a,c Turbine Pressure (20% TP) [

]a,c Rack Temperature Effect (RTE)

Steam Flow (100% TP)

[

]a,c Steam Flow (20% TP)

[

]a,c Turbine Pressure [

]a,c Rack Drift (RD)

Steam Flow (100% TP)

[

]a,c Steam Flow (20% TP)

[

]a,c Turbine Pressure (100% TP) [

]a,c Turbine Pressure (20% TP) [

]a,c

In percent flow span (135.9 % Span).

Values are converted to flow span via Equation 3-27.8:

Where Fmax = 135.9 %, FN (steam flow 100) = 114 % and FN (steam flow 20) = 40 %.

Therefore, gain1 (steam flow 100) = [

]a,c and gain2 (steam flow 20)

= [

].a,c Turbine pressure is converted to DP Span with a gain3 [

].a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 97 Table 3-19A (continued)

High Steam Line Flow - SI, Steam Line Isolation Rosemount 1153DD6 - Steam Flow, Rosemount 1153GB8 - Turbine First Stage Pressure High Steam Flow - 100% Turbine Power Channel Statistical Allowance =

a,c a,c High Steam Flow - 20% Turbine Power Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 98 Table 3-19A (continued)

High Steam Line Flow - SI, Steam Line Isolation Rosemount 1153DD6 - Steam Flow, Rosemount 1153GB8 - Turbine First Stage Pressure High Steam Flow - 100% Turbine Power Safety Analysis Limit (1)

=

124.5% full steam flow Nominal Trip Setpoint (2)

=

114.0% full steam flow Instrument Span

=

135.9% full steam flow Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

114.4 full steam flow Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

High Steam Flow 20% Turbine Power Safety Analysis Limit (1)

=

60.0% full steam flow Nominal Trip Setpoint (2)

=

40.0% full steam flow Instrument Span

=

135.9% full steam flow Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

41.2 full steam flow Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam flow & turbine first stage pressure may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the high steam line flow, SI

& steam line isolation functions with steam line flow & turbine first stage pressure provided by Rosemount 1153DD6 & 1153GB8 transmitters, respectively. This configuration represents the bounding (worst case) CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 99 Table 3-19B Steam Line Flow - High, SI, Steamline Isolation Rosemount 3154ND4 - Steam Flow, Rosemount 3154NG5 - Turbine First Stage Pressure Process Measurement Accuracy (PMA) a,c

[

]a,c

[

]a,c

[

]a,c

[

]a,c

[

]a,c

[

]a,c Primary Element Accuracy (PEA)

Steam Flow

[

]a,c Turbine Pressure

[

]a,c Sensor Calibration Accuracy (SCA)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Sensor Reference Accuracy (SRA)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Sensor Measurement & Test Equipment Accuracy (SMTE)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Sensor Pressure Effects (SPE)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Sensor Temperature Effects (STE)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 100 Table 3-19B (continued)

High Steam Line Flow - SI, Steam Line Isolation Rosemount 3154ND4 - Steam Flow, Rosemount 3154NG5 - Turbine First Stage Pressure Parameter Allowance*

Sensor Drift (SD) a,c Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Environmental Allowances (EA)

Steam Flow Turbine Pressure Bias Sensor Drift Bias (Bias1)

Seismic bias (Bias2)

Rack Calibration Accuracy (RCA)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c Rack Measurement & Test Equipment Accuracy (RMTE)

Steam Flow (100% TP)

[

]a,c Steam Flow (20% TP)

[

]a,c Turbine Pressure (100% TP) [

]a,c Turbine Pressure (20% TP) [

]a,c Rack Temperature Effect (RTE)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure

[

]a,c Rack Drift (RD)

Steam Flow(100% TP)

[

]a,c Steam Flow(20% TP)

[

]a,c Turbine Pressure(100% TP) [

]a,c Turbine Pressure(20% TP) [

]a,c In percent flow span (135.9 % Span).

Values are converted to flow span via Equation 3-27.8:

Where Fmax = 135.9 %, FN (steam flow 100) = 114 % and FN (steam flow 20) = 40 %.

Therefore, gain1 (steam flow 100) = [

]a,c and gain2 (steam flow 20)

= [

].a,c Turbine pressure is converted to DP Span with a gain3 [

].a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 101 Table 3-19B (continued)

High Steam Line Flow - SI, Steam Line Isolation Rosemount 3154ND4 - Steam Flow, Rosemount 3154NG5 - Turbine First Stage Pressure High Steam Flow - 100% Turbine Power Channel Statistical Allowance =

a,c a,c High Steam Flow - 20% Turbine Power Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 102 Table 3-19B (continued)

High Steam Line Flow - SI, Steam Line Isolation Rosemount 3154ND4 - Steam Flow, Rosemount 3154NG5 - Turbine First Stage Pressure High Steam Flow - 100% Turbine Power Safety Analysis Limit (1)

=

124.5% full steam flow Nominal Trip Setpoint (2)

=

114.0% full steam flow Instrument Span

=

135.9% full steam flow Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

114.4 full steam flow Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

High Steam Flow 20% Turbine Power Safety Analysis Limit (1)

=

60.0% full steam flow Nominal Trip Setpoint (2)

=

40.0% full steam flow Instrument Span

=

135.9% full steam flow Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

41.2 full steam flow Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam flow & turbine first stage pressure may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the high steam line flow, SI

& steam line isolation functions with steam line flow & turbine first stage pressure provided by Rosemount 3154ND4& 3154NG5 transmitters, respectively. This configuration represents the best case CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 103 Table 3-20 Tavg - Low, SI, Steam Line Isolation Parameter Allowance*

a,c Process Measurement Accuracy (PMA) a,c Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA) a,c Sensor Calibration Accuracy (SCA) a,c Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift (SD) a,c Sensor Measurement and Test Equipment (SMTE)

Bias a,c ERI Rack Calibration Accuracy (RCA) a,c Rack Measurement & Test Equipment Accuracy (RMTE) a,c Rack Temperature Effect (RTE) a,c Rack Drift (RD) a,c Alpha****

In percent span (100 °F) a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 104 Table 3-20 (continued)

Tavg - Low, SI, Steam Line Isolation Calculating the average temperature uncertainty measurement when multiple RTDs are considered:

a,c NH = 2 (Number of Hot Leg RTDs). It is assumed that one Hot Leg RTD is out of service (3 - 1 = 2).

NC = 1 (Number of Cold Leg RTDs). It is assumed that one Cold Leg RTD is out of service (2 - 1 = 1).

a,c Calculating the average uncertainty for the ERI card:

a,c Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 105 Table 3-20 (continued)

Tavg - Low - SI, Steam Line Isolation Safety Analysis Limit (1)

=

539 °F Nominal Trip Setpoint (2)

=

543 °F Instrument Span

=

100 °F Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

542.7 °F Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 106 Table 3-21A Steam Generator Pressure - Low SI, Steam Line Isolation - Outside Containment Steam Break Rosemount 1153GB9 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effect (SPE)

Sensor Temperature Effect (STE)

Sensor Drift (SD)

Sensor Environmental Allowance (EA)

Bias a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (1400 psig)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 107 Table 3-21A (continued)

Steam Generator Pressure - Low SI, Steam Line Isolation - Outside Containment Steam Break Rosemount 1153GB9 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 108 Table 3-21A (continued)

Steam Generator Pressure - Low SI, Steam Line Isolation - Outside Containment Steam Break Rosemount 1153GB9 Safety Analysis Limit (1)

=

555.0 psig Nominal Trip Setpoint (2)

=

614 psig Instrument Span

=

1400 psig Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

607 psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam generator pressure may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the steam generator pressure low, SI &

SLI (outside containment steam break) functions with steam generator pressure provided by a Rosemount 1153GB9 transmitter. This configuration represents the bounding (worst case) CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 109 Table 3-21B Steam Generator Pressure - Low SI, Steam Line Isolation - Outside Containment Steam Break Rosemount 3154NG5 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effect (SPE)

Sensor Temperature Effect (STE)

Sensor Drift (SD)

Sensor Environmental Allowance (EA)

Bias a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (1400 psig)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 110 Table 3-21B (continued)

Steam Generator Pressure - Low SI, Steam Line Isolation - Outside Containment Steam Break Rosemount 3154NG5 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 111 Table 3-21B (continued)

Steam Generator Pressure - Low SI, Steam Line Isolation - Outside Containment Steam Break Rosemount 3154NG5 Safety Analysis Limit (1)

=

555.0 psig Nominal Trip Setpoint (2)

=

614 psig Instrument Span

=

1400 psig Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

607 psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam generator pressure may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the steam generator pressure low, SI &

SLI (outside containment steam break) functions with steam generator pressure provided by a Rosemount 3154NG5 transmitter. This configuration represents the best case CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 112 Table 3-22A Steam Generator Pressure - Low SI, Steam Line Isolation - Inside Containment Steam Break Rosemount 1153GB9 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effect (SPE)

Sensor Temperature Effect (STE)

Sensor Drift (SD)

Sensor Environmental Allowance (EA)

Bias a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (1400 psig)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 113 Table 3-22A (continued)

Steam Generator Pressure - Low SI, Steam Line Isolation - Inside Containment Steam Break Rosemount 1153GB9 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 114 Table 3-22A (continued)

Steam Generator Pressure - Low SI, Steam Line Isolation - Inside Containment Steam Break Rosemount 1153GB9 Safety Analysis Limit (1)

=

566.3 psig Nominal Trip Setpoint (2)

=

614 psig Instrument Span

=

1400 psig Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

607 psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam generator pressure may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the steam generator pressure low, SI &

SLI (inside containment steam break) functions with steam generator pressure provided by a Rosemount 1153GB9 transmitter. This configuration represents the bounding (worst case) CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 115 Table 3-22B Steam Generator Pressure - Low SI, Steam Line Isolation - Inside Containment Steam Break Rosemount 3154NG5 Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effect (SPE)

Sensor Temperature Effect (STE)

Sensor Drift (SD)

Sensor Environmental Allowance (EA)

Bias a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (1400 psig)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 116 Table 3-22B (continued)

Steam Generator Pressure - Low SI, Steam Line Isolation - Inside Containment Steam Break Rosemount 3154NG5 Channel Statistical Allowance =

a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 117 Table 3-22B (continued)

Steam Generator Pressure - Low SI, Steam Line Isolation - Inside Containment Steam Break Rosemount 3154NG5 Safety Analysis Limit (1)

=

566.3 psig Nominal Trip Setpoint (2)

=

614 psig Instrument Span

=

1400 psig Total Allowance

=

a,c Channel Statistical Allowance(4)

=

Margin

=

Allowable Value(2)

=

607 psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

4.

Steam generator pressure may have multiple transmitter configurations due to replacement transmitters. This table reflects the evaluation of the steam generator pressure low, SI &

SLI (inside containment steam break) functions with steam generator pressure provided by a Rosemount 3154NG5 transmitter. This configuration represents the best case CSA for this function.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 118 Table 3-23 Containment Pressure - High-High Containment Spray, Steam Line Isolation, Containment Phase B Isolation Parameter Allowance*

a,c Process Measurement Accuracy (PMA)

Primary Element Accuracy (PEA)

Rack Drift Bias (RD_HHBias)

Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (47 psi)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 119 Table 3-23 (continued)

Containment Pressure - High-High Containment Spray, Steam Line Isolation, Containment Phase B Isolation Channel Statistical Allowance =

a,c a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 120 Table 3-23 (continued)

Containment Pressure - High-High Containment Spray, Steam Line Isolation, Containment Phase B Isolation Safety Analysis Limit (1)

=

25 psig Nominal Trip Setpoint (2)

=

20 psig Instrument Span

=

47 psig Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

20.7 psig Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 121 Table 3-24 Steam Generator Water Level - High-High, Feedwater Isolation Rosemount 3154ND2 Parameter Allowance*

a,c Process Measurement Accuracy a,c Primary Element Accuracy (PEA)

Sensor Reference Accuracy (SRA)

Sensor Calibration Accuracy (SCA)

Sensor Measurement & Test Equipment Accuracy (SMTE)

Sensor Pressure Effects (SPE)

Sensor Temperature Effects (STE)

Sensor Drift (SD)

Bias a,c Environmental Allowance (EA) a,c Rack Calibration Accuracy (RCA)

Rack Measurement & Test Equipment Accuracy (RMTE)

Rack Temperature Effect (RTE)

Rack Drift (RD)

In percent span (100% RTP)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 122 Table 3-24 (continued)

Steam Generator Water Level - High-High, Feedwater Isolation Rosemount 3154ND2 Channel Statistical Allowance =

a,c a,c Note: Negative sign () denotes direction (i.e. indicated lower than actual).

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 123 Table 3-24 (continued)

Steam Generator Water Level - High-High, Feedwater Isolation Rosemount 3154ND2 Safety Analysis Limit (1)

=

96.8% span Nominal Trip Setpoint (2)

=

80.0% span Instrument Span

=

100% span Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

80.5% span Process Racks +/- As Found Tolerance (AFT) (3)

=

a,c Process Racks +/- As Left Tolerance (ALT)(3)

=

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.2-1 of the plant Technical Specifications.

3.

Based on Rack Calibration Accuracy (RCA) in % Span.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 124 Table 3-25 Containment Radiation - Gaseous Parameter Allowance*

a,c Statistical fluctuations of the algorithm (UVA/Alg)

Beta efficiency (UVA/primcal)

Secondary efficiency (UVA/2ndcal)

Tertiary efficiency (UVA/tercal)

Setting Tolerance efficiency (UVA/settol)

Signal treatment (UVA/ST)

Temperature (UVA/T)

Relative humidity (UVA/RH)

Pressure effect (UVA/P)

Analog output uncertainty (UVA/AO)

Statistical fluctuations of the algorithm (BVA/Alg)

Beta efficiency (BVA/primcal)

Values are in Hz. Span is 16 ma.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 125 Table 3-25 (continued)

Containment Radiation - Gaseous Channel Statistical Allowance (CSA) = Total Loop Uncertainty (TLU)

TLUNGM216_P =

a,c a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 126 Table 3-25 (continued)

Containment Radiation - Gaseous Safety Analysis Limit (1)

=

N/A Nominal Trip Setpoint (2)

=

(1.11 x 10-3) / F Ci/cc Instrument Span

=

ma_Span = 16 ma

=

6 decades typical Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

(1.17 x 10-3) / F Ci/cc AS-Left and As-Found Criteria Particulate Setpoint +/- ALT =

a,c Particulate Setpoint +/- AFT =

Allowable Value is determined by the AFT.

RG is Radiation Gaseous.

RG_AV =

a,c RG_AV =

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.6-1 of the plant Technical Specifications.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 127 Table 3-26 Containment Radiation - Particulate Parameter Allowance*

a,c Statistical fluctuations of the algorithm (UVA/Alg)

Beta efficiency (UVA/primcal)

Secondary efficiency (UVA/2ndcal)

Tertiary efficiency (UVA/tercal)

Setting Tolerance efficiency (UVA/settol)

Signal treatment (UVA/ST)

Temperature (UVA/T)

Relative Humidity (UVA/RH)

Pressure effect (UVA/P)

Analog output uncertainty (UVA/AO)

Statistical fluctuations of the algorithm (BVA/Alg)

Beta efficiency (BVA/primcal)

Values in Hz. Span is 16 ma.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 128 Table 3-26 (continued)

Containment Radiation - Particulate Channel Statistical Allowance (CSA) = Total Loop Uncertainty (TLU)

TLUNGM216_P =

a,c a,c a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 129 Table 3-26 (continued)

Containment Radiation - Particulate Safety Analysis Limit (1)

=

N/A Nominal Trip Setpoint (2)

=

9.00 x 10-8 Ci/cc Instrument Span

=

ma_Span = 16 ma

=

6 decades typical Total Allowance

=

a,c Channel Statistical Allowance

=

Margin

=

Allowable Value(2)

=

9.45 x 10-8 Ci/cc AS-Left and As-Found Criteria Particulate Setpoint +/- ALT =

a,c Particulate Setpoint +/- AFT =

Allowable Value is determined by the AFT.

RP is Radiation Particulate.

RP_AV =

a,c RP_AV =

Notes 1.

As noted in Chapter 14 or not included in Chapter 14 but used in the Safety Analysis.

2.

As noted in Table 3.3.6-1 of the plant Technical Specifications.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 130 Table 3-27 P Measurements Expressed in Flow Units The P accuracy expressed as percent of span of the transmitter applies throughout the measured span, i.e., +/- 1.5 % of 100 inches P = +/- 1.5 inches anywhere in the span. Because F2 = f(P) the same cannot be said for flow accuracies. When it is more convenient to express the accuracy of a transmitter in flow terms, the following method is used:

P

=

)

F

(

N 2

N

where N = Nominal Flow P

=

F F

2 N

N N

thus F

2 P

=

F N

N N

Eq. 3-27.1 Error at a point (not in percent) is:

P 2

P

=

)

F 2(

P

=

F F

N N

2 N

N N

N

Eq. 3-27.2 and

)

F

(

)

F

(

=

P P

2 2

N N

max max

Eq. 3-27.3 where max = maximum flow and the transmitter P error is:

=

(100)

P P N max

percent error in Full Scale P (% FS P)

Eq. 3-27.4

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 131 Table 3-27 (continued)

P Measurements Expressed in Flow Units Therefore,

F F

(2)(100)

P FS

=

F F

P 2

100 P

FS P

=

F F

N 2

N N

max max max max

Eq. 3-27.5 Error in flow units is:

F F

(2)(100)

P FS F

=

F N

2 N

N max

Eq. 3-27.6 Error in percent nominal flow is:

F F

2 P

FS

=

(100)

F F

N 2

N N

max

Eq. 3-27.7 Error in percent full span is:

F F

2 P

FS

=

(100)

F F

(2)(100)

P FS F

F

=

(100)

F F

N N

2 N

N max max max max

Eq. 3-27.8 Equation 3-27.8 is used to express errors in percent full span in this document.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 132 4.0 APPLICATION OF THE SETPOINT METHODOLOGY 4.1 Uncertainty Calculation Basic Assumptions / Premises The equations noted in Sections 2 and 3 are based on several premises. These are:

1)

The instrument technicians make reasonable attempts to achieve the NTS as an as left condition at the start of each process racks surveillance interval.

2)

The process rack drift will be evaluated (probability distribution function characteristics and drift magnitude) over multiple surveillance intervals. Process rack drift is defined as the arithmetic difference between previous as left and current as found values.

3)

The process rack calibration accuracy will be evaluated (probability distribution function characteristics and calibration magnitude) over multiple surveillance intervals.

4)

The process racks, including the bistables, are verified/functionally tested in a string or loop process.

It should be noted for (1) above that it is not necessary for the instrument technician to recalibrate a device or channel if the as found condition is not exactly at the nominal condition, but is within the two-sided ALT. As noted above, the uncertainty calculations assume that the ALT (conservative and non-conservative direction) is satisfied on a reasonable, statistical basis, not that the nominal condition is satisfied exactly. This evaluation assumes that the RCA and RD parameter values noted in Tables 3-1 through 3-26 are satisfied on at least a two-sided 95 % probability / 95 % confidence level basis. It is therefore necessary for the plant to periodically reverify the continued validity of these assumptions.

This prevents the institution of non-conservative biases due to a procedural basis without the plant staffs knowledge and appropriate treatment.

In summary, a process rack channel is considered to be calibrated when the two-sided ALT is satisfied. An instrument technician may determine to recalibrate if near the extremes of the ALT, but it is not required. Recalibration is explicitly required any time the as found condition of the device or channel is outside of the ALT. A device or channel may not be left outside the ALT without declaring the channel inoperable and appropriate action taken. Thus, an ALT may be considered as an outer limit for the purposes of calibration and instrument uncertainty calculations.

From the above it should be noted that the discussion was limited to the ALT. Nothing was said with respect to the AFT. That is because, for Westinghouse supplied process racks, drift is expected to be small with respect to the ALT.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 133 Statistical evaluations of Westinghouse supplied process racks have determined that an operable process rack channel with an as left condition near the NTS should have an as found condition near the NTS on the next surveillance, and well within the two-sided ALT about the NTS. Thus, Westinghouse has concluded that for operable racks AFT = ALT = RCA.

The above results in the Westinghouse Setpoint Methodologys reliance on the NTS and not the Limiting Trip Setpoint (LTSP) as defined in ISA 67.04.01-2006 (1) or the Limiting Setpoint (LSP) as defined in RIS 2006-17 (2). Specific to Reference 2, the LSP is noted as: the limiting setting for the channel trip setpoint (TSP) considering all credible instrument errors associated with the instrument channel. The LSP is the limiting value to which the channel must be reset at the conclusion of periodic testing to ensure the safety limit (SL) will not be exceeded if a design basis event occurs before the next periodic surveillance or calibration. As noted on the previous page, with respect to the Westinghouse Setpoint Methodology, operability of the process racks is defined as the ability to be calibrated about the NTS (ALT about the NTS) and subsequent surveillance should find the channel within the AFT = ALT about the NTS. On those rare occasions that the channel is found outside of the AFT = ALT, then operability requirements would be initially satisfied via recalibration, or reset, about the NTS. Operability defined as conservative with respect to a zero margin LSP is a concept that is insufficient for the Westinghouse Setpoint Methodology and is inconsistent with its basic assumption of the AFT = ALT = RCA definition. In order to have confidence (statistical or otherwise) of appropriate operation of the process racks, it is necessary that the process racks operate within the two-sided limits defined about the NTS. This is particularly true for protection functions that have historical NTS values that generate large Margins. From a Westinghouse Setpoint Methodology perspective, systematic allowance of large drift magnitudes in excess of equipment design - either by large magnitude RD or RMTE terms or utilization of an LSP, generates a false sense of security which is inappropriate for future operation consideration, and which erodes the concept of performance based specifications and limits.

4.2 Process Rack Operability Determination Program and Criteria The parameter of most interest as a first pass operability criterion is relative drift (as found - as left) found to be within RD, where RD is the two-sided 95/95 drift value assumed for that channel.

However, this would require the instrument technician to record both the as left and as found conditions and perform a calculation in the field. This field calculation requires having the as left value for that device at the time of drift determination and Turkey Point Units 3 and 4 have elected to have a plant specific requirement to determine if the drift allowance assumptions were exceeded since the last calibration activity.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 134 An alternative for the process racks is the Westinghouse method for use of a fixed magnitude, two-sided AFT about the NTS. It would be reasonable for this AFT to be RMTE + RD, where RD is the actual statistically determined 95/95 drift value and RMTE is defined in the Turkey Point Units 3 and 4 procedures. However, comparison of this value with the RCA tolerance utilized in the Westinghouse uncertainty calculations would yield a value where the AFT is less than the RCA tolerance (ALT).

This is due to RD being defined as a relative drift magnitude as opposed to an absolute drift magnitude and the process racks being very stable, i.e., no significant drift. Thus, it is not reasonable to use this criterion as an AFT in an absolute sense, as it conflicts with the second criterion for operability determination, which is the ability of the equipment to be returned to within its calibration tolerance. That is, a channel could be found outside the absolute drift criterion, yet be inside the calibration criterion. Therefore, a more reasonable approach for the plant staff was determined. An AFT criterion based on an absolute magnitude that is the same as the RCA criterion, i.e., the allowed deviation from the NTS on an absolute indication basis is plus or minus the RCA tolerance (ALT). A process loop found inside the RCA tolerance (ALT) on an indicated basis is considered to be operable.

A channel found outside the RCA tolerance (ALT) is evaluated and recalibrated. The channel must be returned to within the ALT, for the channel to be considered operable. This criterion is incorporated into plant, function specific calibration and drift procedures as the defined ALT about the NTS. At a later date, once the as found data is compiled, the relative drift (as found-as left) can be calculated and compared against the RD value. This comparison can then be utilized to ensure consistency with the assumptions of the uncertainty calculations documented in Tables 3-1 through 3-

26. A channel found to exceed this criterion multiple times should trigger a more comprehensive evaluation of the operability of the channel.

The Turkey Point Units 3 and 4 systematic program of drift and calibration review used for the process racks is acceptable as a set of first pass criteria. More elaborate evaluation and monitoring may be included, as necessary, if the drift is found to be excessive or the channel is found difficult to calibrate.

Based on the above, the total process rack program used at Turkey Point Units 3 and 4 will provide a more comprehensive evaluation of operability than a simple determination of an acceptable as found.

4.3 Application to the Plant Technical Specifications The drift operability criteria described for the process racks in Section 4.2 would be based on a statistical evaluation of the performance of the installed hardware. Thus this criterion would change if the M&TE is changed, or the procedures used in the surveillance process are changed significantly and particularly if the process rack modules themselves are changed. Therefore, the operability criteria are not expected to be static. In fact they are expected to change as the characteristics of the equipment change. This does not imply that the criteria can increase due to increasingly poor performance of the equipment over time; but rather just the opposite.

As new and better equipment and processes are instituted, the operability criteria magnitudes would be expected to decrease to reflect the increased capabilities of the replacement equipment.

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 135 For example, if the plant purchased some form of equipment that allowed the determination of relative drift in the field, it would be expected that the rack operability would then be based on the RD value.

Sections 4.1 and 4.2 are basically consistent with the recommendations of the Westinghouse paper presented at the June 1994, ISA/EPRI conference in Orlando, FL(3). In addition, the plant operability determination processes described in Sections 4.2 and 4.3 are consistent with the basic intent of the ISA paper (1).

Therefore the AVs for the Turkey Point Units 3 and 4 Technical Specifications are performance based and are determined by adding (or subtracting) the calibration accuracy (RCA=ALT) of the device tested during the Channel Operational Test to the NTS in the non-conservative direction (i.e.,

toward or closer to the SAL) for the application.

Two examples of the AV, ALT and AFT calculations are as follows:

Power Range Neutron Flux - High Allowable Value Determination ALT/AFT Determination NTS =

108% RTP NTS =

108% RTP SPAN = 120% RTP SPAN = 120% RTP RCA =

[

]a,c RCA =

[

]a,c SAL =

115% RTP ALT =

[

]a,c AV =

[

]a,c ALT =

[

]a,c AV =

[

]a,c ALT =

[

]a,c AV =

108.6% RTP AFT =

[

]a,c AFT =

[

]a,c AFT =

[

]a,c

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-18888-NP February 2024 Revision 0 136 Steamline Pressure - Low (SI)

Allowable Value Determination ALT/AFT Determination NTS =

614 psig NTS =

614 psig SPAN =

1400 psig SPAN = 1400 psig RCA =

[

] a,c RCA =

[

] a,c SALin =

566.3 psig SALout = 555.0 psig ALT =

[

] a,c AV =

[

] a,c ALT =

[

] a,c AV =

[

] a,c ALT =

[

] a,c AV =

607 psig AFT =

[

] a,c AFT =

[

] a,c AFT =

[

] a,c 4.4 References / Standards 1.

ANSI/ISA-67.04.01-2006, "Setpoints for Nuclear Safety-Related Instrumentation," May 2006.

2.

NRC Regulatory Issue Summary 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, Technical Specifications, Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels, August 2006.

3.

Tuley, C. R., Williams, T. P., The Allowable Value in the Westinghouse Setpoint Methodology

- Fact or Fiction presented at the Thirty-Seventh Power Instrumentation Symposium (4th Annual ISA/EPRI Joint Controls and Automation Conference), Orlando, FL, June 1994.

Turkey Point Nuclear Plant L-2024-008 Docket Nos. 50-250 and 50-251 ENCLOSURE 4 Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-24-002 (3 pages follow)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-002 Page 1 of 3 Commonwealth of Pennsylvania:

County of Butler:

(1)

I, Zachary Harper, Senior Manager, Licensing, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2)

I am requesting the proprietary portions of WCAP-18888-P Revision 0 be withheld from public disclosure under 10 CFR 2.390.

(3)

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

(4)

Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i)

The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii)

The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii)

Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-002 Page 2 of 3 (5)

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

(a)

The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b)

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

(c)

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

(d)

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

(e)

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

(f)

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

(6)

The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower-case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-002 Page 3 of 3 I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 1/30/2024 Signed electronically by Zachary Harper Executed on: 1/30/2024 Signed electronically by

v t e Letter Sequence Supplement
EPID:L-2023-LLA-0161, License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles (Approved, Closed)
Initiation Request Acceptance Supplement, Supplement Administration Withholding Request Acceptance, Withholding Request Acceptance Questions 6 September 2024 6 September 2024 17 September 2024 8 October 2024 Answers 3 October 2024 31 October 2024 Results Approval, Approval, Approval, Approval Other:
MONTHYEAR2024-03-01 [Table View]

ML24040A190

Text

References:

Enclosures:

1.0 BACKGROUND

2.0 DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REFERENCES

1.0 BACKGROUND

2.0 DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REFERENCES

3.1 BACKGROUND

3.1 BACKGROUND

3.2 BACKGROUND

3.2 BACKGROUND

3.2 REFERENCES

1.0 INTRODUCTION

1.0 INTRODUCTION

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