Text

Measurement Uncertainty Recapture Fple/Caldon - NRC Meeting
	ML072710548
Person / Time
Site:	Seabrook
Issue date:	12/16/2005
From:	Estrada H, Hale S, Hauser E; Caldon, Florida Power & Light Energy Seabrook
To:	; Office of Nuclear Reactor Regulation
References
	FOIA/PA-2007-0255
	Download: ML072710548 (77)
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MEASUREMENT UNCERTAINTY RECAPTURE FPLE/CALDON - NRC MEETING December 16, 2005 Steve Hale Herb Estrada Sb Ernie Hauser PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 1 trademarks of Caldon, Inc. All rights reserved.

FPLEnergy _: = _ _

Seabrook Station Proposed Agenda

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Introductory Remarks - NRC, FPL Energy, Caldon Principles of Operation; the LEFM CheckPlusTM System Discussion, Topical Areas of Concern (will follow the outline of the attachment to the meeting notice)

Laboratory Testing - Caldon*

Plant Installation - Caldon, FPL Energy UFM Operation - FPL Energy, Caldon Conclusions; Action Items PR542 *Caldon, LEFM, LEFM Check, and CheckPlus are registered 2 trademarks of Caldon, Inc. All rights reserved.

FPL Energy Seabrook Station LEFM Principles -

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The volumetric flow in a pipe is given by the integral of the axial velocity over the cross sectional area of the pipe pipearea Q-= v (x,y)dxdy axial PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 3 trademarks of Caldon, Inc. All rights reserved.

FPL Energy EZl\ El I= o x AF Rw -

Seabrook Station LEFM Principles S*.*.-...'..~

What the elapsed times of transiting pulses measure

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V C =sound velocity of fluid at rest

.4' tdown = Lpath/(C + V) tup = Lpath/(C - V)

At = tup - tdown = 2 Lpalh V/(C 2 ,- V 2 )

tuptdown = Lpath 2 /(C 2 - V 2)

V = (2) At (Lpath/ tuptdown)

Lpath V (V2) At (Lpath 2 / tuptdown)

C = L/[tup/2 + tdowj 2 ]

For further study, TP-44 (Reference Tab 4 of INFO-19)

PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 4 trademarks of Caldon, Inc. All uights reserved.

FPL Energy LZ=ZYE 0 ==F-\ o Seab LEFM Principles The UFM measures the transit times of ultrasonic pulses traveling in each direction along each acoustic path and uses these data to determine the average fluid velocity and the average sound velocity along each chord.

But the time measured includes more than the transit time through the fluid.

tmeasured - telec + ttransducers + tcable + tfluid + tdetection Cable Cable PR542 5

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy Seabrook Station LEFM P:

An 8-path chordal LEFM-the LEFM CheckPlus used for MUR uprates A4-6ý /

In the 8 path configu ation,

( The 4 path LEFM CheclcijII

, ;,ý U[efby transverse velocity

\// but its sensitivity is low (- 0.2%)

in most hydraulic locations PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 6 trademarks of Caldon, Inc. All rights reserved.

FPL Energy Seabrook Station LEFM Principles R ,

Ultrasonic pulses are generated and detected in an electronics unit, which also processes the transit time measurements and performs the mass flow and temperature calculations Seabrook Electronics Unit shown 7 "Caldon, LEFM, LEFM Check, and CheckPlus are registered PR542 trademarks of Caldon, Inc. All rights reserved.

FPL Energy ~ZZJLIi~ U F Lcz~E~ u W

Seab rook Station LEFM Princies-Chordal LEFMs determine volumetric flow by numerically integrating the axial velocity at 4 pre-selected chordal locations The LEFM measures the integral of WzID W3ID Vaxial (x) dx at each location.

The volumetric flow is determined by umming the flow contribution of the four seg ents. Each contribution is calculated as the pr uct of the width of the segment, (wi

ID), d the Vdx integral for that segment.

Y i -- --- ,------- Y The low sensitivity of the resul to axial velocity profile has been determined by analysis and by WO/

l00s of hydraulic tests in a wide range of .a 0 configurations. y?*e ,2' PR542 8

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy 7L-2 n = =1

,

Seabrook Station LEFM Principles 1111111111=

. * . . :. "..

. . . . . . ....

The chordal LEFM Mass Flow Algor

(ID/2) > w iLffi (Ati)/2-Wf =P

PF*Fa3 (T) i., tan(Vi) p= f (T, p) A, /

xzý T=fT (Cmean, P) 4 Cmean = Fa, (T) [w, Lffi ]/[ti + (Ate/2)- ]-i i=I Uncertainties Property functions and pressure measurement, Dimensions, Hydraulics (axial profile), Time Measurements PR542 *Caldon, LEFM, LEFM Check, and CheckPlus are registered 9 trademarks of Caldon, Inc. All rights reserved.

LEFM Principles FPL Energy Representative Mass Flow £ZZ7E2 LI! OThZ~E~ C I 5' ~

--

Seabrook Station Uncertainties for LEFM CheckPlus TOTAL POWER UNCERTAINTY DETERMINATION Parameter(l) ER-157P Seabrook Station Uncertainty Uncertainty

1. Hydraulics: Profile factor 0.25% 0.20%

2. Geometry: Spool dimensions, alignment, thermal 0.09% 0.10%

expansion

3. Time Measurements: Transit times and non fluid 0.045% 0.07%(")

time delay

4. Feedwater Density:(2) LEFM temperature 0.07% 0.07%

determination, pressure input, and correlation _ __

5. Subtotal: Mass flow uncertainty 0.28% 0.24%

(Root sum square of items 1, 2, 3, and 4 above)

6. Feedwater Enthalpy:(3) LEFM temperature 0.08% 0.08%

determination, pressure input, and correlation _ __

7. Steam Enthalpy: Pressure input and moisture 0.07% 0.08%

uncertainty

8. Other Gains and Losses 0.07% 0.03%

9. Total Power Determination Uncertainty 0.33%(4) 0.30%

Notes for Table are included in handout

Caldon, LEFM, LEFM Check, and CheckPlus are registered PR542 10 trademarks of Caldon, Inc. All rights reserved.

FPL Energy EA7LiEl fC==DE:%0 Seabrook Station LEFM Principles In an 8 path meter, transverse 1up .5dn velocity vectors projections are essentially equal and opposite on paired acoustic paths IT In a 4 path meter transverse projections due to swirl cancet

iies*wirl is centere Projections ldn of "Goertler" vortices (from a 5up single bend) also tend to cancel when summed.

PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy ~ZZ7L2 0 U~E~ C I z~~-- =

Seabrook Station LEFM Principles Chordal LEFMs measure the axial velocity profile, characterizing it by its Flatness, the ratio of the outer path average velocity to the inner path average velocity For a 4 Path LEFM F =(V + V4)

(V2 + V3)

For an 8 path LEFM F = (V1+V4+V5+V8)

(V2+V3+V6+V7)

PR542 12

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy Seabrook Station LEFM Pri Axial profiles in nuclear feedwater systems can vary widely Inertial effects dominate Wall roughness can be an important factor Reynolds Number is a relatively small and inconclusive factor 0.,

BUT When the chordal paths are located in accordance with the rules of Gaussian quadrature numerical 0, integration, the calibration of a 4 path chordal meter is not very OA sensitive to axial profile. The graph plots the Profile Factor against 1.

flatness, over the range of profiles seen in nuclear feedwater systems PR542 13

Caldon, LEF L M Check, Pd CPeckPlus are registered trademas ofC~aldon, Inc. 11rights rserved..

0FPL Energy Q E7lZ =C=11 0 Seabrook Station LEFM Principles i .:':"'. "' '"................

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Sensitivity to swirl and other factors Because transverse velocities cancel in an 8 path chordal LEFM, swirl and other vortices do not affect calibration significantly, except as they affect axial profile Experience has shown that the 4 path system integrates moderately asymmetric axial profiles within -0. 1%

PR542 14

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FPL Energy Seabrook Station LEFIF 4 Principles In contrast, an external UFM is constrained to measure a velocity along a diametral path An externally mounted transit time meter measures the diametral average axial velocity The relationship between diametral average axial velocity and cross-sectional average axial velocity is sensitive to profile shape PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 15 trademarks of Caldon, Inc. All rights reserved.

FPL Energy ~7L2 fl !Thc2~E\ 0 Seabrook Station LEFM Principles

E The relative sensitivities of A chordal and external UFMs to axial velocity profile. are shown in the graph on the right

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"-'4 PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy £Z:ZiZL 0 E;= 0 Seabrook Station 1. Laboratory Testing a Ar == -

The tests calibrate the flow element for a spectrum 4 f hydraulic conditions; they establish the Profile Factor, PF, as a function of Flatness and also form the basis for the uncertainty in the Profile FactLor Test Plan ALD-1081 Rev. 1 (Reference Tab 5 of INFO 18)

Purpose, ARL and Caldon Responsibilities, Prerequisites, Tests, and Documentation Scheduled for January 16-20, 2006 PR542 4C7 08Idon, LEFM, LEFM Check, and CheckPlus are registered II trad,emarks of Caldon, Inc. All rights reserved.

I, FPL Energy £7L2 0 C===

AW S& ;w' Seabrook Station Lab Facility

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FIGURE I

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I 01"4ýý A414;1 BUILDINB #l FLOW *EASMiEFENT FACILITIES

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Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

0FPL Energy cz7Lz~ o UZ~c~E~

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~m-Seabrook Station 1. Laboratory Testing -- ------

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Full scale model testing of the Beaver Valley 2 flow eleMent 11 PR542 19

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

0 FPLEnergv Seab rook Station 101 Laboratory Testing -

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The Main Feedwater system at Seabrook (PID-1-FW-B20687)

Feedwater pumps to the four feeds to the steam generators P&ID and Isometric Drawings are included in the handout PR54Q2 20 Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy 1.1 Laboratory Testing GZL\0 = =MCI Seabrook Station A description of the test configurations Test B-I Reference configuration 50-50 Flow split 25 weigh tank runs; 5 flow rates over a -4:1 range of flows PLANT MODEL TEST B-1 FLOW SPLIT - 50/50 SKEJM 1.DWG KRB 12-12-05 PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 21 trademarks of Caldon, Inc. All rights reserved.

FPL Energy Laboratory Testing £zaz7c-49 arm-e Uee~

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Seabrook Station A description of the test configurations

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Test B-2 Minimum branch flow 25-75 Flow split 15 weigh tank runs; 3 flow rates over a -2.5: 1 range of flows

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11ý1 MITSUBiS-II FLOW CONDITIONER LEFM SPOOL 36" ýC 24" METERING RE-DUER SECTION PLANT MODEL TEST B-2 FLOW SPLIT - 25/75 SKEJM-30-2.DWG KRB 12-12-05 PR542 22

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

6FPL Energy 1.1 Laboratory Testing z=a l C==

Seabrook Station A description of the test configurations Test B-3 Maximum branch flow 75-25 Flow split 15 weigh tank runs; 3 flows over a -2.5:1 range of flows LEFM SPOOL 36" . 24" METERING REOUCER SECTION PLANT MODEL TEST B-3 FLOW SPLIT - 75/25 SKEJM-30-3.DWC KRB 12-12--05 PR542 23

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy 1.1 Laboratory Testing czzz= rzc=CarEl Seabrook Station A description of the test configurations

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Test B-4, Upstream Profile Sensitivity Remove Flow Conditioner upstream of Branch 50-50 Flow split 25 weigh tank runs over a -4:1 range of flows LEFM SPOOL 36" x 24" MEIERING REDUCER SECTION PLANT MODEL TEST B-4 FLOW SPLIT -- 50/50 SKEJM-30-4.DWG KRB 12-12-05 PR542 24

4Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rghts reserved.

0FPL Energy 1.1 Laboratory Testing 'CA [I =o Seabrook Station A description of the test configurations Test B-5 Maximum Swirl Test Half moon plate upstream of 45 degree bend in branch 50-50 Flow split 25 weigh tank runs over a -4:1 range of flows LEUM SPOOL 36" x 24" MEIERrNC REDUCER SECTIrON PLANT MODEL TEST B-5 FLOW SPLIT -- 50/50 SKEJM-- 30-5.DWG KRB 12-12-05 PR542 Caldon, LEFM, LEFM Check, and CheckPlus are registered 25 trademarks of Caldon, Inc. All rights reserved.

FPL Energy 1.1 Laboratory Testing */-X----* 22h r-xo Seabrook Station A description of the test configurations

............................-.... -

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.......................

Test A-I Straight pipe-A benchmark and low flatness datum 25 weigh tank runs over a -4:1 range of flows LEFM SPOOL METERINC SECTION PLANT MODEL STRAIGHT PIPE TEST SKEJM- 30-O. DWG KRB 12--12-05 PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 26 trademarks of Caldon, Inc. All rights reserved.

FPL Energy 1.2 Laboratory Testing Q Eo Seabrook Station Description of supporting analyses T hePreliminarv Uncertainty Analysis for Seabrook, EFP-61, Commissioning Procedure for the LEFM electronics used in the calibration tests (Reference Tab 7 of INFO 18)

A test procedure that establishes the signal quality, coherent noise level, non fluid time delays, etc.for the lab equipment, thereby establishing the time measurement uncertaintiesfor the calibrationtest.

PR542

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FPL Energy 1.2 Laboratory Testing Seabrook Station Description of supporting analyses.

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. ....... ~ :____._____.,.___________..

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A profile factor calculation and uncertainty assessment will be issued for the Seabrook flow element following the calibration tests. Examples of previous reports are r* *wx low.

R -287 Rev. 1, the .F Calculationand Accuracy Assessment for D C Cook I (Reference T b 9 of INFO 18)

FCDP-118,Field C mmissioning Data Package which includes the data for EFP-61forth Cook 1 flow element (Reference Tab 8 of INFO 18)

PR542

Caldon, LEEM, LEFM Check, and CheckPlus are registered 28 trademarks of Caldon, Inc. All rights reserved.

FPL Energy 1.2 Laboratory Testing Z Seabrook Station Description of supporting analyses

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v :**;**** '; ;; ' ; '*irs :`. . .. **

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A new revision to the Seabrook Uncertainty analysis, incorporating the results of the calibration tests will be issued after these tests are complete.

An example is referenced below.

ER-2 75 Rev 2 (Reference Tab 1 of INFO 18) The final uncertainty analysisfor D.C. Cook 1, incorporatingthe results of the calibration tests and the plant commissioning PR542

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0FPL Energy 1.3 Laboratory Testing c~I7LI1 I ~

o ~~L2 0 Seabrook Station Summary of data from each lab test

.........................

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............................-. ~

The calibration reports and dates for all calibration tests performed for LEFM Check and CheckPlus flow elements (Reference Tab 1 ofINFO 9 - (Q-1.3.1 No data are excluded from any calibration test (Q-1.3.2) 0, ER 486 Rev. 1 (Reference Tab 2 ofINFO 18) is a c pilation of ca ibration data for 44 LEFM Check and CheckPlus flow elements ,4/9,A ,.

41 PR542

Caldoh, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy 1.3 Laboratory Testing £ZZ7ý 0 L~cE Seabrook Station Summary of data from each lab test A sample of the data in ER-486: D.C. Cook Unit 2 Extrapolation to plant conditions based on Flatness is shown DC Cook Unit 2 1.050 Alden 1.040 A Plan(

I-inear (Theoretical slope) 1.030 1.020 1.010 0

U-1.000 7

IL 0.990 0.980 0.970 0.960 0.950 0.750 0.800 0.850 0.900 0.950 1.000 1.050 Flatness Ratio PR542

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FPL Energy 1.3 Laboratory Testing ý 511i101 ThTh1 Seabrook Station A summary of data from each lab test 4 '

An ISO from ER-486: D.C. Cook Unit 2 I-Ut-A 131 DETAIL C JSFPIRTMY NDSaJORT DEA!L NUMBE ETAIL "B"

Caldon, LEFM, LEFM Check, and CheckPlus are registered PR542 32 trademarks of Caldon, Inc. All rights reserved.

FPLEnrg ~.4 Laboratory Testing 0_ =iE Seabrook Station Noise Issues

/4: U V.

1B 11 0 (Reference Tab 4o6INFO 18), was issued on September 2003 anad t- raulic noise and vibrations on chordal LEFMs LEFM Receiver pass band (700 kHz to 3 MHz) is above mechanical vibration frequencies of piping systems Pressure pulstions can cause sound velocity variations but effects on LEFM less thaf .0.05%ybounded by uncertainty allowance for turbulent velocity variations Coherent and random noise from acoustic or electronic sources can cause errors in the measurement of transit time differences-At's Measurement errors due to random noise can be reduced to negligible magnitudes by multiple samples Measurement errors due to coherent noise can be significant and must be controlled if the instrument is to remain within its design basis PR542 33

Caldon, LEFM, LEFIVM Check, and CheckPlus are registered trademarks of Caldon. Inc. Atl rights reserved.

sv"'ý47'A F =1 Energy 1.4 Laboratory Testing _ __ N =[:I Setabrook Station Noise Issues LEFMs measure time from the initiation of pulse transmission to the zero crossing of the first positive ________

half cycle of the received signal-the transit time including non fluid delays n, I

The graphs show the effect of coherent noise-a shift in the time at which the first zero crossing of the received signal occurs SNRC = the ratio of the received signal to the SNRC --. 1.0 MHz Transducers coherent noise that is present Max At error = (1/SNRC)x(Transducer Period)/rr The' amplitude f the received signal must be monitore to en ure that SNRC remains within acceptable limi The signal aggregate noise ratio is also monitored PR542 PR542 ,~j

Caldon, LEFM, LEFM Check, and CheckPlus are registered Caldon, LEFM, trademarks LEFM Inc.

FPL Energy 1.4 Laboratory Testing cz712 o c~cz~c~ o I ~

Seabrook Station Noise Issues Coherent noise as well as other potential sources of time measurement errors must be monitored in the lab tests as well as in the plant to ensure that This source of uncertainty in the Profile Factor determination is appropriately bounded Time measurement errors in the plant flow determination remain within their budget emperature changes, either spatially or temporarily, do not introduce errors in a transit time UFM eyy can degrade the statistics of the transit time measurements rt thereby requiring larger measurement samples to achieve desired accuracy PR542

Caldon, LEFM, LJEFM Check, and CheckPlus are registered 35 trademarks of Caldon, Inc. All rights reserved.

1.5.1 Laboratory Testing FPL Energy Application of Lab Test Results I==M l Seabrook Station to Plant; Swirl On one occasion, the calibration of an LEFM CheckPlus was questioned after 1.004 installation. The calibration tests had failed to model non planar upstream features. Consequently the swirl in the plant 1A1111 wasn'ibrat greater than that in ioI tmewas the model.

performed lI "i ing a 16 inch prototypeTH ec lus w

ý,element ("Sputnik").-e ry w -- svely, producing the

ýA'data at the right.

he sensitivity of the chordal meter to

0 lreasing swirl (the lower curve) is entirely due to the increased flatness produced by the swirl.

An adjustment of 0.06% to the plant I

R-293, (Reference Tab 3 of INFO 18) 15% 20%

Swil. % of 25%

x.al v.l.Ity 30%

PR542 36

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

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1.5.2 Laboratory Testing FPL Energy Application of Lab Test Results *ZZ7'-X[

wEA 0 a--2tZ*--- V Seabrook Station to Plant Interpolation/extrapolation of lab test results to plant conditions is jperf~orteon the basis of Flatness Lh_

a_

(see ER-486)

Fla captures plant-lab differences due to inertial effects, wall roughness AND Reynolds Number In the examples shown (Loop B 1.015 I I 12 I 1 I I I11 1I I I I 1 .010 LEFM at Millstone 3) flatness 1 .005 I

I II I I I

i I II I

I I I

I I

I 1l I1 11l I I1 I

I I I 2

I I I 1 I II and RN yield identical results I II I I II I I I1 iI I I I J.1 1 1 LL 1.000 I ,L I I -- I I I I1 I / I I I1 i I ] I I II II In-plant commissioning tests are 0.995

' ~ *I II I I I I I 0.990 covered later in the presentation 0.985 3.0 Reynolds Num ber/1,000,000 0 33-0-67

...- 'Theoretical Sensitivity 0 100-0-0

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1.6 Data Analysis Summary FPL Energy Uncertainty Analysis 1= =Ca 0 Seabrook Station of the Calibration Data The 130 weigh tank runs for the 6 hydraulic configurations in which the Seabrook flow element will be tested will be analyzed to determine its profile factor vs. flatness characteristic. These data, along with th si na nois and non fluid transit delay data of EFP-61 will also be used to rablish e the uncertainty in the profile factor The elements of the uncertainty in profile factor include:

Facility uncertainty Observational (turbulence, etc.) uncertainty Time measurement uncertainty Modeling and (Flatness) curve fit uncertainty (extrapolation/interpolation to plant conditions)

The results of the analysis of the Seabrook data will be published in a flow element specific report A typical analysis of calibration data has been cited on an earlier slide (1.6.1)

ER -287, the PFCalculation and Accuracy Assessment for D C Cook 1 PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 38 trademarks of Caldon, Inc. All rights reserved.

1.6 Data Analysis Summary FPIL Energy Uncertainty Analysis e== 0 ==M Seab rook Station of the Calibration Data ER-287 Rev. I also describes the application of the calibration data to the plant installation (Q-1.6.2) -

The final revision of the uncertainty analysis fo C. Cook 1, (ER-2 75 Rev 2, cited previously) is an example of the analysis of ovewater temperature, and thermal power determination uncertainties, incorporating the results of the calibration tests, as well as the commissioning data of the LEFM in the plant The methodology for establishing instrument uncertainties follows ASME PTC 19.1 and is described in detail on Caldon Topical Reports ER-80P and ER-157P PR542 39

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1.6.3 Traceability of 0FPL Energy Laboratory Testing and a AVEIsfJ EZwZiEý Seabrook Station Plant Installation to NIST The Traceability of LEFM Check and CheckPlus measurements has been the subject of an ANS technical paper Traceabilityof Thermal Power Measurements, Part1, Chordal UltrasonicFlow Measurements D. Augenstein, et al.,

- (Reference Tab 7 of INFO 19) 4th International Topical Meeting on Nuclear Plant Instrumentation, Control and Human Machine Interface Technology. September, 2004 PR542 A A Caldon, LEFM, LEFM Check, and CheckPlus are registere*d

1.6.3 Traceability of 0FPL Energy Laboratory Testing and La~zZ0l =C=M 0 I~~W~In Seabrook Station Plant Installation to NIST PFPFu + dPF . F dF F - flatness = f(R4., Roughness, upstream hydraulic configuration)

F = (X*(outside chord velocities))/ (E (inside chord velocities)) The diagram opposite, extracted I

Facility measurements, Flow element calibration at certified hydraulic facility, baseline from the paper, illustrates the weight, time, T. and P, traceable pere calibrations tractable configuration p(F) Qv -(weight, time, ~p(T,..,P_*))

traceability of the calibration data in NI ST QM(~~,t**

(profile factor) as applied in the UFM time '

traceable to, NI' ht*pe; et nywn facility to establishyrui sensitivity of calibration PF ofgrtosa etFie yrui to flatnessmauenn, plant - TP76 Figure 1. Length measurements requi red for flatness

-

dPF =leaft(

dF PF1 - PF.__*

(F - FO)

(Reference Tab 7 of INFO 19) calculation) also tractable. ,

Determine flatness Fr in the field; establish PF for field installation Fri = O,-u (outside chord velocities))/ (inside chord velocities))

UFM time and length measurements, PFt = PFu + dPF , Fro required for field dF 4

ieasurement of flatness, traceable. Set threshold for change in flatness, AFT Confirmation that change in flatness AFT= I/dPF x aPF(F) dF-remains within threshold confirms that shape of axial profile Wite OPF (F) is the allowance for profile shape uncertainty is the remains within meter uncertainty analysis allowance for profile change in meter 4

For subsequent flow measurements in the field, confirm flatness is uncertainty analysis. within threshold:

F,-= (E (outside chord velocities)y (L. (inside chord velocities))

46 I(F.r- Fso)I<AFT? lf'so, measurement is valid.

If not, measurement is rejected.

PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 41 trademarks of Caldon, Inc. All rights reserved.

FPL"Energy 2. Plant Installation cz :1i~El 1=1=m 0 Seabrook Station 2.1 Specification for the UFM

. . . . -.-

. . .. . . . .. . . .. . . ..

The FPL Energy purchase FPL Bnergv S.Ibr- 1 P-,,0 U11390 R.,

sb-n, 0ll S.ko.k Std..o specification is the governing TABLE OF CONTENTS document (Reference Tab 10 of Cow RMoe

]Rword af Re~i A UN of Affwold Ps&es B I

INFO 18) Tall. of comots 1.0 GE EA IN .RKA . .............

.-.......-....-

... --.....

'1 Srr ATIONAD.ES

- .

Ii DEF~flIONS The preliminary uncertainty analysis 1.6 1.7 MUUStJWLIEO.....-

.....

DEVIA71ONSAND1NCINCONFORMANfCES- .....

. . . .

. .

-

....

-.... . -

19 DIISCLAB6666 ...... ~- ....... .

for Seabrook, ER-482, previously 2.0 hC1ON`CAL REQUOUDONTO.......6 2.2 WOIM INCLUDED. ~ ~.... .

cited, forms the performance 22 24 RELATEDWORKNOT OOJOD-.

DEMON1 FERIFORMAŽ101 REUIt2166.4Th- . .-.

2.6 oEruAnlNO RE UZJ~EM .- .--..--.. .

specification for the LEFM .... ..-.. ...3 2.1 FABRICATIN.-.0-..H-2.9 EE.ECTION.-. ..-...... ~.... -- ~

2-10 C TO .. - -

2.1 TIM- -N I CLEAYM40

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2. 1S64. SOH FS - - E-U 1 . --. .-- - - . . ..... . .-..... .. - - .1-. -

213 UNCERTA2n7YCALCULATIONS AND NRCUCEN9D4USUPPORT-.-.............23 2.16 TECHNICALSERVICEREQWREh4]R ___S.. s 2.17 HANDI0NG,SKIPPING, AND STORAGE...-

-- .

2.18 D10SBLOflS-- - - - - 26

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2.20 BOUINDARYDE"INHION.................. . . ................. - . . .... ........- ...... 2 22 1 MMGMAOrION AND (TIRRHSFONDENCE .F 2.22 OPTIONS..... ..................-

FPL Energy 2. Plant Installation Seabrook Station 2.1 Specification for the UFM -

..... ~~ ~

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"-:""'*,*,* M k3 LEFM Uncertainties versus Flow , Errors as a function of feed flow and temperature, LEFM perties fixed at 170 Fbelow 250 F Rate Volumetric Flow:

Most error contributors affect the measurement as a % of reading.

Exception: At errors which affect the measurement as a

% of rated flow Mass flow:

Follows volumetric flow, density error due to temperature is a small % of reading /.V Mass flow %rated PR542 Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy 2. Plant Installation LYZY LIX C]

-- a~

OZIXCThE2 C

-

Seabrook Station 2.1 Specification for the UFM

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.* . s-~. ~. ~ ~**'-d~-,'r~sc- 1 &j~t ~

LEFM Uncertainties versus Flow Rate Sound Velocity vs. Temperature In pure water at 1000 pals Temperature derived from 64000 sound velocity can only be 620D0 used above temperatures

- 250' F. 680000 Between this temperature and 150'F the RTD provides the 540M mass flow computation and temperature output 'C52000 01 Temperature errors range W from +/-1.5 degrees at 200 F to 48000

+/-0.6 degrees at 430 primarily because of the changing slope 46000 0 50 100 150 250 250 300 350 400 450 500 of the temperature-sound Temperature, degrees F velocity curve PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 44 trademarks of Caldon, Inc. All rights reserved.

FPL Energy 2. Plant Installation__

Seabrook Station 2.2 Flow conditioners "

As discussed in the calibration test slides, flow conditioners are used in calibration testing to "homogenize" upstream hydraulic effects LEFM Check or CheckPlus flow elements are typically not installed downstream of flow conditioners in nuclear feedwater systems Tests of chordal LEFMs in petroleum applications show that flow conditioners should be installed about 15 diameters upstream of the flow element if a lab calibration is to be transferred to the field Experience in petroleum applications shows that tube type flow straighteners preserve distortions in axial profile that would otherwise dissipate PR542 45

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy 2. Plant Installation LZ227E\ 0 I --

~E~E1 0 Seabrook Station 0 ~U 2.3 Description of Feedwater System 2.3.1 P&ID and Isometric Drawings are included in the handout PR542 PR542 46trademarks 46 of Caldon, Caldon, LEFM, LEFMInc. All rights Check, reserved. are registered and CheckPlus

FPL FP Energy 2. Plant Installation cz zc=

Seabrook Station 2.3 Description of Feedwater System 2.3.2 Hardware that can affect the profile The model includes The lateral Bend upstream of the lateral branch Reducer upstream of lateral straight The model does not include The long straights, planar bends and non planar bends from the outlet water boxes of the HP feedwater heaters These effects are bounded by the test with the flow straightener upstream of the branch elbow removed and by the test with the "half moon" plate installed upstream of the branch /,,

PR542

Caldon, LEFM, LEFM Check, and CheckPlus are registered 47 trademarks of Caldon, Inc. All rights reserved.

FPL Energy 2. Plant Installation Seabrook Station 2.3 Description of Feedwater System 2.3.2 Hardware that will not affect the profile 1 1/2 inch vent and drain connections are located - 5 diameters upstream of the LEFM. The interfaces between the connections and the ID of the upstream pipe are flush. The lines are capped. Experience with similar connections show that they will not affect the axial profile seen by the LEFM _

The tubes of the feedwater heaters act to eliminate the impact, on the profile, of hydraulic features upstream of the heaters The 25-75 and 75-25 flow split tests bound the effects of operations with a heater bypassed PR542 48

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

FPL Energy 2. Plant Installation _ E 0 Seabrook Station 2.3 Description of Feedwater System 2.3.3 Potential bypass flow paths A sample connection immediately downstream of the LEFM is used intermittently to sample the chemistry of the feedwater. It is a 'A inch connection and, if in service, would result in a negligible but conservative flow error.

1 inch chemistry injection connections in each of the individual steam generator feeds (4 total) are used only to inject chemicals during steam generator wet lay-up 4 inch emergency feedwater connections to each steam generator (4 total) can inject feed only if the emergency feedwater pumps are in operation, not a normal full power condition j-

Conclusion:

No plausible bypass paths PR542

FPL Energy 2. Plant Installation cz 2c0 EZ -\L0 Seabrook Station 2.4 Rationale for LEFM Location FPL Energy Criteria Caldon Criteria Located inside (OE with Capability to model existing system) Access for installation and Facilitate maintenance maintenance Consistent with the guidelines PR542

FPL Energy 2. Plant Installation 21 Seabrook Station 2.5 Pre-operational Test Configurations The parametric approach to calibration tests for LEFM CheckPlus flow elements obviates the need for varying feedwater system configuration A change in configuration may change the axial profile Axial profile is monitored to ensure that it remains within allowable variation (+/-0.05 ch ge in Flatness) established at Commissioning Experience shows at changes in flatness exceeding +0.05 are extremely unusual , 2. ,*

Data supporting these conclusions can e found in Caldon Engineering Report ER-262 (Reference Tab 5 of INFO 19)

Spatial and temporal variations in feedwater temperature do not affect LEFM performance.

2. Plant Installation FPL Energy 2.6 Comparison and Evaluation of Lab =, =

Seabrook Station Test Configurations with Plant InstallationsW 2.6.1 Assessment of changes in profile between the laboratory test and the plant installation BE-48-6rovides calibration data for a comprehensive sample of

---installations, showing the Flatness measured in plant for each.

For

,Itseveral of the installations variations in Flatness in plant are also

(..ER-262 cpntains a comprehensive listing of measured variations in

-Flatnes- for 16 installations. Appendices describe the circumstances of two significant variations (Flatness changes of 0.04 to 0.05)

Caldon certifies the LEFM performance for all practical upstream hydraulic configurations including variations in lineup, wall roughness, and feedwater temperature/viscosity PR542

2. Plant Installation FPL Energv 2.6 Comparison and Evaluation of Lab Q E ==

Seabrook Station Test Configurations with Plant Installations -

.I--

2.6.2 Changes in profile are detected by changes in Flatness wh automatically measured and alarmed if a change exceed There are no restrictions on the LEFM in terms of tot fib flow rate in either branch of the lateral upstream o e LE FM

~ZA/y~4&1~

lAy

'a le

-~ 6).

A AI*

"?a PR542

2. Plant Installation FPL Energy 2.6 Comparison and Evaluation of Lab £ZZI

Seabrook Station Test Configurations with Plant Installations

.-.-

2.6.3 This question has been addressed in previous slides.

Comment. While Caldon has used computationalfluiddynamics for parametricanalyses offlow effects (e.g., the distortion of the flow field produced by the transducerapertures in smallflow elements) we have found that the CFD methodology is generally not accurate or traceable enough to use to establishprofilefactors.

PR542

2. Plant Installation FPL Energy 2.6 Comparison and Evaluation of Lab ==0 Seabrook Station Test Configurations with Plant Installations s I-

.* *-.'.:-" ,"*' .* ".... "..

2.6.4 The calibration process establishes the sensitivity of the profile factor to profile flatness. The uncertainty in applying this relationship to the plant conditions, as established by the flatness measured during commissioning is typically in the order of +/-0.1 %

a2. Plant Installation FPL Energy 2.6 Comparison and Evaluation of Lab = [

Seabrook Station Test Configurations with Plant Installations -

2.6.5 The effect of noise in the plant Coherent acoustic and electronic noise can cause errors in the measurement of At's To ensure that the errors due to noise remain within the bounds budgeted in the site specific uncertainty analysis:

During commissioning, the magnitudes of the received signals, coherent noise, and random noise are measured in each direction for each acoustic path, to ensure that potential errors from these sources are within the uncertainty budget The magnitude of the received signals is continuously monitored during subsequent operation of the LEFM. If the signal strength on any acoustic path falls below the level at which the signal/coherent noise ratio is acceptable (from the standpoint of the budgeted uncertainty) that signal is rejected. Continuous rejections cause a path to be declared "out of service" and the meter will enter the "maintenance mode" with increased uncertainty (and therefore a lower allowable thermal power).

In addition, a diverse back up, the ratio of signal strength to the aggregate noise (coherent plus random) is also used as a measure of signal acceptability

a2. Plant Installation 2.6 Comparison and Evaluation of Lab =

FPL Energy EZl7 Seabrook Station Test Configurations with Plant Installations '

2.6.6 Effect of pipe roughness changes An increase in pipe roughness will tend to decrease the flatness of the axial profile (because it makes the profile more rounded). The change in profile factor should be characterized by the parametric calibration tests. Typically, an increase in roughness will change the calibration by less than 0.1 %, within the uncertainty budget for such effects.

PR542 57

2. Plant Installation FPL Energy 2.6 Comparison and Evaluation of Lab zrna Elz Seabrook Station Test Configurations with Plant Installations 2.6.7 An examination of the evaluation results ER-262 and ER-486 provide a comprehensive database comparison between profiles encountered in lab calibration and encountered in the plant Important observations are:

2 -- Plant profiles cannot be precisely predicted in the laboratory Profiles are subject to change over time and in fact, change in 100% of the cases d-, Therefore, an allowance must be maintained to account for meter factor change commensurate with profile changes observed. The

+/-0.11% accounted for modeling uncertainty covers this effect for LEFM CheckPlus Systems

FPL Energy 2. Plant Installation Seabrook Station 2.7 Duration of Data Collection During Lab Calibration For each run, filling the weigh tank takes between 40 seconds and 3 minutes to complete depending on flow rate The LEFM performs flow calculations with a frequency of about 50 Hz Thus the number of flow samples N per weigh tank run ranges between 2000 and@ý /V'/-

The standard deviation of each flow sample due to turbulence is - 2%.

The standard deviation of the average flow reading for a weigh tank run is reduced by the large number of flow samples. However the reduction is not as great as 1/(N)'1 because the periods of some of the turbulent

.eA frequencies are only I order shorter than the weigh tank fill time The uncertainties due to these statistics are accounted as the observational uncertainty contributor to the profile factor uncertainty PR542

FPL Energy 2. Plant Installation L cEc= 0 Seabrook Station 2.7 Duration of Data Collection In the plant A sample period greater than 2 minutes will generally reduce uncertainties due to turbulence to - 0.1 %

However, a longer averaging period may be necessary to reduce observational uncertainties due to limit cycling of the feedwater regulating valves A longer averaging period-in the 5 minute range-may also be required to ensure that the measurement is representative of thermal equilibrium between the reactor/steam generators and the power conversion system Seabrook will use an LEFM rolling average of 30 seconds to be consistent with the 4 minute, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months rolling averages currently used at the plant PR542 60 *Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All rights reserved.

2. Plant Installation FPL Energy 2.8 Evaluation of UFM D =_ 1 Seabrook Station Operational Characteristics -

....

.. " >*-*.'*.*]*

" ... . . 7*,'2* *.":',...*."- *..-. %,-.-.* ..* .-._-, *. -..: ....

EFP-61 is performed to commission the LEFM in-plant Signal Quality is confirmed (e.g., coherent and random signal noise ratios, reciprocity of upstream and downstream received signals)

Non fluid time delay inputs are confirmed by in-plant measurements for each acoustic path Settings for individual path alarms are established Upstream and downstream gains (signal magnitude)

Upstream and downstream signal/(aggregate) noise ratios (diverse backup to the gain alarms)

Individual path reciprocity requirements are established Allowable variations in transit times and At's are established, for use in signal processing filters PR542

2. Plant Installation FPL Energy 2.8 Evaluation of UFM Seabrook Station Operational Characteristics Flatness is measured for each 4 path acoustic plane and for the 8 path system as a whole The appropriate profile factor for operation in the 8 path (CheckPlus) mode is established The range of acceptable changes to Flatness is established to obtain the settings for the high and low flatness (profile change) alarms The profile factors for each acoustic plane are established for use when one plane is out of service (with reduced system accuracy in the "maintenance mode")

Settings for other system level alarms are established Allowable variation in individual path sound velocity versus average sound velocity firom all paths PR542 "Caldon, LEFM, LEFM Check, and CheckPlus are registered 62 trademarks of Caldon, Inc. All rights reserved.

FPL Energy 2. Plant Installation c~7L2O E~ZD~E~ IJ

- -- - -

Seabrook Station 2.9 Vendor Validation and Certification The final revision of the uncertainty analysis engineering report incorporates the results of the commissioning process ER-275 (for D.C.Cook) has been provided as an example (Reference Tab 1 of INFO-18)

The Caldon letter forwarding the final revision of the uncertainty analysis also forwards a certificate of compliance for the UFM installation An example is shown (Reference Tab 9 of INFO-19)

PR542 63

3. UFM Operation FPL Energy 3.1 Description of the UFM's EA E,-,

[] 11 Seabrook Station error analysis methodology -

Table 6-1 of ER-80P lists the bounding, validation, and verification procedures for each elemental uncertainty of the uncertainty analysis of Appendix E of that document. The table also applies to the uncertainty analysis of Appendix A of ER- 157P (for CheckPlus Systems). Table 6-1 demonstrates that all error contributors that can plausibly change in the short tenri in the field are alarmed.

Note: The table indicates that item 5c, signal to coherent noise ratio, is not alarmed. The LEFM does provide alarm protection for this variable in the form of a high gain (low signal strength) alarm.

PR542 64

03. UFM Operation FPLEnergy 3.1 Description of the UFM's _ __

Seabrook Station error analysis methodology - -

3.1.1, 3.1.2 Changes in profile are recognized by changes in the measured flatness. An allowance for changes in flatness is included in the error budget. The allowance takes the form of a profile factor uncertainty - +/-0.1 %. If a measured change in flatness exceeds that which would cause a change in calibration exceeding 0. 1%

(flatness change -0.05), the condition is alarmed, the meter is considered "failed", and its output is not used.

The discussion in 3.1.2 appears to imply that errors in the LEFM are detected by comparing its indication with other plant indications. The LEFM does not rely on other plant indications for the detection of errors. Nevertheless, licensees are encouraged to perform calculations to determine a "best estimate" of the feedwater flow, as a diverse check. Caldon Information Bulletin CIB-121, Appendix A, (Reference Tab 11 ofINFO-18), describes a rigorous process for forming a best estimate.

PR542

3. UFM Operation FPL Energy 3.1 Description of the UFM's £ZZlti\ n rmcm~~ o 2 U Seabrook Station error analysis methodology - - -. -...

3.1.3 Operational limits on the use of the UFM There are no operational limits on the use of the LEFM 3.1.4, 3.1.5 Effect of operating at operational limits, Cross Checking These topics are not applicable to LEFM Check and CheckPlus Systems PR542

3. UFM Operation FPL Energy 3.1 Description of the UFM's £EZZ7L2 U E £ZD~E~ U Seabrook Station error analysis methodology 3.1.6 Effect of differing temperatures in the two feeds to the main feed header Temperatures of the two feeds may differ by 1P or 2'F during normal operation and may differ by as much as 300 or 40'F if one of the two heaters is out of service, isolated and bypassed. Experience with similar situations in other installations shows the following:

Whether the lateral mixes the fluid or not, the LEFM will measure the bulk average feedwater temperature within its design basis accuracy

(+/-0.6 degrees) because the sound velocity is numerically integrated over the pipe cross section (unlike RTDs which are point measurements).

If significant streaming (varying spatial temperature gradients) is present, it may be necessary to increase the set point for the system alarm on path sound velocity differences.

PR542

/ Streaming can also increase variations in transit time, which may require broadening the statistical filter setting on this variable. (This measure was necessary to obtain an accurate reactor outlet temperature measurement in the presence of a coolant temperature gradient of about 200).

FPL Energy 3. UFM Operation Seabrook Station 3.2 Control Room Procedures Operations personnel reviewed LAR and procedures to identify required changes Procedures revised to reflect MUR power level Maintenance Department - I&C notified of system alarms Allowed Outage Time (AOT), and Action Statement requirements are provided in LAR 05-04 Attachment 1, Section 2.4 (page 2-10)

Will be incorporated as a Limiting Condition for Operation (LCO) in the Technical Requirements Manual Although Caldon Topical Report provides an uncertainty for loss of one plane of LEFM Checkplus TM, power will be reduced to pre-MUR levels when required by TRM Action Statements PR542. .68

FPL Energy 3. UFM Operation a -1 Seabrook Station 3.2 Control Room Procedures Technical Requirements Manual

- Power to be reduced to pre-MUR power level prior to exceeding 48-hours

- Power change of 10% during AOT, limits power level to pre-MUR level

- Loss of the main plant computer system will require reduction in power to pre-MUR level prior to the next daily calorimetric calibration PR542 69

FPL Energy 3. UFM Operation Seabrook Station 3.3 Personnel Training One of significant lessons learned with industry over power events was over reliance on vendor expertise Took an aggressive approach to training General description of training provided in LAR 05-04, Attachment 1, Section 2.4 (Page 2-8)

Training courses at Caldon to train the trainers

- Engineering and Maintenance personnel Specific training for operators as part of the licensed operator training classes prior to the refueling outage PR542 70

t3. UFM Operation FPL-Energy 3.4 Operational Experience with _=Z*l D MD Seabrook Station Currently Installed UFM's "

. .2 Flow rates in the individual steam generator leads are currently measured by two path chordal ultrasonic flow elements designed and built by another t vendor When the vendor no longer supported these nuclear installations, Seabrook contracted with Caldon to provide signal processing electronics (an LEFM 8300) so that the instruments could be used as a check on the venturis FPL Energy Experience No operational experience with the Caldon LEFM CheckPlusTM Older devices installed since original plant startup

- Maintenance, Engineering, and Operations personnel very familiar with maintenance and operation of the system

- Primary maintenance issues have been weather exposure and obsolescence PR542 71

0FP L E=nergy

3. UFM Operation 3.5 Time dependent plant conditions c: [ *z

Seal irook Station that might affect UFM performance ER-262, previously cited, describes changes in velocity profiles that have

,been measured in nuclear feedwater systems. One case, documentedi-n Appendix A of that report, describes a significant change in axial profile and swirl brought about by a marked decrease in wall roughness as evidenced by a flattening of the axial profile and increased swirl. The change in roughness is believed to have occurred as a result of several days of operation in the "cold recirculation" mode, at high pH. As described in the reference, the effect of the change in flatness on the LEFM calibration was less than 0.1%.

The error was conservative Corrosion products do not preferentially deposit on the ID of the LEFM flow element (as they do in the throat of a flow nozzle). The interior diameter of the flow element is monitored by periodic measurement of the wall thickness, under the ISI program. A conservative allowance for wall thickness change (+ 15 mils) is included in the ER- 15 7P uncertainty analysis PR542

3. UFM Operation FPL Energy 3.6 Available comparisons of _ ,

Seabrook Station UFM indications with other parameters -

Topic does not appear to apply to Seabrook since UFM is not yet installed.

As noted previously, comparisons with other plant parameters are not necessary to validate LEFM operation.

Nevertheless Caldon encourages users to form a "best estimate" of feedwater flow using diverse other indications. The best estimate methodology is described in Appendix A of CIB-121 Rev. 0, referenced earlier.

FPL Energy Monitoring primary and secondary parameters Existing UFMs and venturies provide additional feedwater flow indication Evaluating additional "best-estimate" methods, including River Bend method PR542

3. UFM Operation FPL Energy 3.7 Participation in Caldon Seabrook Station Nuclear Users' Group (CNUG) -

Agendas and attendees for the annual meetings of CNUG are provided (Reference Tab 8 ofINFO 19)

FPL Energy decision to purchase in 2005 Obtained previous CNUG meeting minutes Reviewed and applied applicable information for previous CNUG meeting minutes into design change Registered in the VIP Room on Caldon Website Will attend Users Group meeting in 2006 PR542 74

Caldon, LEFM, LEFM Check, and CheckPlus are registered trademarks of Caldon, Inc. All tights reserved.

3. UFM Operation FPL Energy 3.8 Responding to information Lanr o ==[:EI 0 Seabrook Station C)btained from Users Group and from CIBs .

Users Group meetings are typically documented under self-assessments Condition Report System used to evaluate

- Issues identified

- Applicable Technical Bulletins

- Applicable operating experience Future applicable Caldon Customer Information Bulletins (CIBs) will be processed through the Condition Reporting System PR542

FPL Energy 3. UFM Operation Seabrook Station 3.9 Past instances maim 1-.... 1 Past instances where UFM flow rate indications would have resulted in plant operation above the licensed power limit There has never been an instance where the use of an LEFM Check or Check Plus system has led to operation above a plant's licensed power level 12 7, 0611ý PR542 76

0FPL Energy 'IF7L SA0A E~EE w Seabrook Station Conclusions; Action Items

--

Open Discussion PR542

ML072710548

Text

Conclusion:

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