Text

License Amendment Request - Expanded Actions for LEFM Conditions
	ML18239A355
Person / Time
Site:	Peach Bottom
Issue date:	08/27/2018
From:	David Helker; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
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ML18239A353	List: ML18239A355;
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	Download: ML18239A355 (170)
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200 Exelon Way Kennett Square, PA 19348 Exelon Generation www.exeloncorp .com PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 10 CFR 2.390 August 27, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Stations, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

License Amendment Request - Expanded Actions for LEFM Conditions

Reference:

(1) Exelon letter to the NRC, "Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate," dated February 17, 2017 (ADAMS Accession No. ML17048A444)

(2) NRC letter to Exelon, "Peach Bottom Atomic Power Station, Units 2 and 3 -

Issuance of Amendments Re: Measurement Uncertainty Recapture Power Uprate," dated November 15, 2017(ML17286A013)

In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) requests an amendment to Renewed Facility Operating License (RFOL) Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively, for off-normal conditions of the Leading Edge Flow Meter (LEFM) ~+ (CheckPlus) system. The Measurement Uncertainty Recapture (MUR) License Amendment Request (LAR) (Reference 1) submitted by EGC for an increase in licensed thermal power based upon the improved accuracy of the LEFM CheckPlus system was approved by the NRC with the issuance of the Final Safety Evaluation Report and RFOL Amendments 316 and 319 for PBAPS Units 2 and 3, respectively (Reference 2).

The LEFM CheckPlus system has been operational at PBAPS since 2002. The MUR LAR, as approved by the NRC, specified the actions to be taken in the event that one or more LEFMs degraded from the CheckPlus (NORMAL) to the Check (MAINTENANCE) or FAIL mode.

Included among those approved actions was authorization to operate at a power level less than the maximum allowable licensed power but greater than pre-MUR level (referred to as an "Intermediate Power Level") when one or more of the LEFMs are in the Check mode.

Attachment 4 transmitted herewith contains Proprietary Information. When separated from Attachment 4, this document is decontrolled.

U.S. Nuclear Regulatory Commission Expanded Actions for LEFM Conditions August27,2018 Page2 The proposed change requested herein would expand the number of Intermediate Power Levels from one to four. Specifically, it would establish three separate Intermediate Power Levels for the LEFM CheckPlus system conditions in which one, two or three LEFMs are in Check mode, with none in FAIL mode. A fourth Intermediate Power Level would be for the LEFM condition in which the flow measurement input to the core thermal power calculation for one of the three feedwater lines is from the differential pressure Feedwater (FW) flow nozzle measurement (venturi) as a result of the associated LEFM being in the FAIL mode or otherwise not available for service. The Intermediate Power Levels correspond to the total power uncertainties conservatively calculated for each of the LEFM conditions. The LEFM system installation at PBAPS is unique in that some of the equipment is not accessible during power operation and a degraded LEFM could require a reactor outage to make repairs. This LAA would allow operation at power levels commensurate with the uncertainties in the measurement of core thermal power.

The proposed changes have been reviewed by the PBAPS Plant Operations Review Committee in accordance with the requirements of the EGC Quality Assurance Program.

EGC requests approval of the proposed changes by June 30, 2019.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), EGC is notifying the Commonwealth of Pennsylvania and the State of Maryland of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Officials. contains an evaluation of the proposed changes including an assessment of how implementation will adhere to the principles of simple decision making for the operator and conservative plant operation.

Attachment 2 contains markups of the proposed Technical Requirements Manual Section 3.20 and the associated Bases (for information only), governing the maximum allowed power levels when any of the LEFMs are in other than the CheckPlus mode.

Attachment 3 provides the EGC PBAPS uncertainty calculation for the FW flow nozzle.

Attachment 4 provides the Cameron Total Power Uncertainty calculations for the three Check mode LEFM conditions. It also combines the FW flow nozzle uncertainty calculated in Attachment 3 with the LEFM uncertainties to determine the Total Power Uncertainty when the flow measurement input for one feedwater line is from the FW flow nozzle.

Attachment 4 provides a proprietary version of the Cameron calculations, ER-464P, "Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 2 Using the LEFM ./+System," Revision 9, and ER-463P," Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 3 Using the LEFM ./+ System," Revision 8. Attachment 5 provides two affidavits executed by Cameron for withholding certain information contained in Attachment 4.

U.S. Nuclear Regulatory Commission Expanded Actions for LEFM Conditions August27,2018 Page 3 provides a non-proprietary version of Attachment 4. In accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding," EGC requests withholding of Attachment 4.

Should you have any questions concerning this request, please contact Mr. David Neff at (267) 533-1132.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 271h day of August 2018.

Respectfully, David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Requirements Manual and Bases Pages (For Information Only)

3. Exelon Calculation PM-1209 Revision 0, "Peach Bottom Feedwater Flow Uncertainty as Measured in the Plant Computer as Measured by the Flow Nozzles Without Calibration by the LEFM"

4. Cameron ER-464P," Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 2 Using the LEFM ./+System," Revision 9 (Proprietary Version), and ER-463P," Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 3 Using the LEFM ./+System," Revision 8 (Proprietary Version)

5. Cameron Affidavit Supporting Withholding Attachment 4 from Public Disclosure

6. Cameron ER-464NP," Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 2 Using the LEFM ./+System," Revision 9 (Non-Proprietary Version), and ER-463NP," Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 3 Using the LEFM ./+System," Revision 8 (Non-Proprietary Version) cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS A. A. Janati, Pennsylvania Bureau of Radiation Protection D. A. Tancabel, State of Maryland

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 1 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 PBAPS LEFM System 2.2 Current LEFM Compensatory Measures 2.3 Proposed Changes to the LEFM Compensatory Measures for LEFM in Check 2.4 Proposed Changes to the LEFM Compensatory Measures for One LEFM in Fail

3.0 TECHNICAL EVALUATION

3.1 Background 3.2 General Approach 3.3 Plant Implementation 3.4 Disposition of NRC Criteria for Use of LEFM Topical Reports 3.5 Deficiencies and Corrective Actions 3.6 Reactor Power Monitoring 4.0 ADDITIONAL CONSIDERATIONS 4.1 Plant Modifications 4.2 Operator Training, Human Factors, and Procedures 4.3 Testing

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria 5.2 Precedent 5.3 No Significant Hazards Consideration 5.4 Conclusions

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 2 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION In February 2017, Exelon Generation Company, LLC (EGC) submitted a Measurement Uncertainty Recapture (MUR) License Amendment Request (LAR) (Reference 1) to revise the Operating License and Technical Specifications (TS) for the Peach Bottom Atomic Power Station (PBAPS) Renewed Facility Operating License (RFOL) Nos. DPR-44 and DPR-56. The 2017 MUR LAR resulted in an increase of 65 megawatts thermal (MWt, approximately 1.66% increase) in rated thermal power (RTP) from 3951 MWt to 4016 MWt. This request was based on the increased accuracy of the Cameron Holding Corporation (hereinafter Cameron) + (CheckPlus) Leading Edge Flow Meter (LEFM) ultrasonic feedwater flow measurement instrumentation relative to the feedwater (FW) flow nozzle differential pressure measurement (venturi or venturi meter) when used in the calculation of reactor core thermal power (CTP). The Cameron LEFM system has two operating modes (CheckPlus and Check); and an inoperable mode (Fail). The NRC issued a Safety Evaluation Report (SER) and approved the requested changes on November 15, 2017, with issuance of RFOL Amendments 316 and 319 for PBAPS Units 2 and 3, respectively (Reference 2). These amendments included authorization to operate at a power level of 4010 MWt after a Technical Requirements Manual (TRM)

Required Compensatory Measures Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if one or more LEFMs remain in the Check mode and no LEFMs are in the Fail mode. Following successful power ascension testing, PBAPS Units 2 and 3 achieved the new licensed power level in January 2018.

The LEFM system has been the primary means of FW flow measurement since its installation following implementation of the initial MUR License Amendments 247 and 250 (Reference 3) in 2003. The licensing basis analyses performed for the Extended Power Uprate (EPU) license amendments received in 2014 (Reference 4) did not incorporate a MUR uprate using the improved accuracy of the LEFM system. Therefore, operation at EPU power levels did not include an MUR uprate or restrictions regarding the status of the LEFM system.

The NRCs Safety Evaluation of Cameron Topical Report ER-157P, Revision 8 (Reference 5) requires that, 1) for any single component failure to the LEFM CheckPlus system, continued operation at the pre-failure power level for a pre-determined time and

2) the decrease in core thermal power that must occur following the pre-determined time are plant-specific and must be justified. Accordingly, the 2017 MUR LAR provided the PBAPS plant-specific justification for 1) continued operation at the MUR uprate power level (i.e., 4016 MWt) for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after one, two or three LEFM(s) degraded to either the Check or the Fail mode and 2) to decrease power level to 4010 MWt if one or more LEFMs remain in the Check mode for greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and none are in Fail mode.

Since implementation of the MUR in 2018, the required compensatory measure if an LEFM changes from the CheckPlus to the Check or Fail mode or is otherwise taken out of service is to switch the FW flow input for the CTP calculation from the affected LEFM(s) to the associated FW lines nozzle within two hours. If any LEFM is in the Fail mode by the end of the TRM Required Compensatory Measures Completion Time, power must be reduced by 65 MWt to the pre-MUR licensed level of 3951 MWt.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 3 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes The LEFM acoustic transducers and cabling are located in the main steam tunnel where the radiation dose rate levels are elevated. This area is a Locked High Radiation Area and inaccessible during normal plant operation. If any of the LEFM components located in the steam tunnel cause the LEFM to be in Fail mode, reactor power is limited to 3951 MWt until the plant is shut down to identify and correct the problem. This installation configuration is unique to PBAPS. The standard LEFM acoustic transducer installation and associated LEFM system equipment is normally installed in plant areas that are accessible during power operations.

The current Maximum Allowable Power Level (MAPL) TRM limit of 4010 MWt when one or more LEFMs are in Check mode and none in Fail mode is based on the Cameron calculations in ER-464/463 Revision 5 (Attachment 1 of Reference 12) which assume that all three LEFMs are in Check mode. The compensatory measures and the intermediate power level for this condition were implemented by a revision to the TRM in January 2018.

This LAR provides the plant-specific analyses to support the proposed compensatory measures for operation of the LEFM system at three separate intermediate power levels for an indefinite period when the mass flow input to the CTP calculation is from one, two or three FW lines in Check mode with none in Fail mode; and a fourth intermediate power level when not more than one LEFM is in Fail mode and flow measurement is being provided by the associated FW flow nozzle. The proposed changes would allow operation at power levels commensurate with the uncertainties in the measurement of core thermal power and reduce the magnitude of the required reactivity maneuver and plant power level change for degradation of the LEFM system.

Since the proposed intermediate MAPL limits are based on total power uncertainties (TPUs) calculated at the same 95% confidence levels as the current MAPL limits, the probability of exceeding the thermal power level for which the Emergency Core Cooling Systems have been analyzed in accordance with 10 CFR 50, Appendix K, remains very low.

The LEFM flow measurement uncertainties are based on the same calculation methodology used to support the MUR LAR (Reference 1, Attachment 8 and Reference 12, Attachment 1). In this LAR, EGC is proposing that credit be taken for the lower uncertainties calculated for the condition when only one or two LEFMS are in the Check mode with none in Fail mode rather than considering that all are in Check mode.

Similarly, the calculation of the TPU for the condition in which one LEFM is in Fail mode is based on the LEFM Check mode uncertainties calculated for the MUR LAR combined with the FW flow nozzle uncertainty calculated for this LAR (Attachment 3).

The Cameron calculations supporting the LEFM FW flow uncertainties, which the four intermediate power levels are based upon, are provided in Attachment 4. The Cameron calculations use the methodology documented in NRC approved Cameron Topical Report ER-157P-A Revision 8 (Reference 5) and the PBAPS MUR Amendments 316 and 319 (Reference 2).

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 4 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes The calculation for the uncertainty associated with the measurement of FW flow by the FW flow nozzle is provided in Attachment 3 and is based on the instrument setpoint uncertainty calculation methodology described in American Society of Mechanical Engineers (ASME) PTC 6 Report (Reference 11).

The TPU for each of the LEFM operating conditions is determined using the square-root-sum-of-squares (SRSS) approach which is the industry accepted method for combining instrument accuracies. The MAPL for each of the four proposed intermediate LEFM operating conditions is then determined by the following equation:

MAPL 4030 MWt / (1+), where 4030 MWt is 102% of pre-MUR licensed power level of 3951 MWt and

= TPU for a particular condition The proposed compensatory measures and intermediate power levels differ from those approved by the NRCs SER for the MUR LAR, although the LEFM uncertainty and TPUs supporting this LAR are consistent with Cameron Topical Report ER-157P-A Revision 8 (Reference 5). The topical report, however, did not consider using the uncertainty associated with FW flow nozzle as an input to a TPU calculation. EGC therefore concluded that NRC pre-approval in the form of a license amendment is required.

2.0 DETAILED DESCRIPTION The changes to the MAPLs associated with each of the LEFM conditions are described in Section 2.2. If approved, they will be incorporated into a revision to TRM Section 3.20 as shown by the marked-up pages provided in Attachment 2. No changes are required to the Operating Licenses or to the TS by this LAR.

2.1 PBAPS LEFM System The PBAPS LEFM System consists of three LEFMs, one on each of the three FW lines.

Each LEFM contains two independent subsystems or planes with each plane containing four acoustic paths. The LEFM system has two operating modes (CheckPlus and Check) and an inoperable mode (Fail). In the CheckPlus mode (also described in this LAR as the Normal mode), both planes of transducers are in service. If an LEFM is subjected to a failure involving a transducer on one plane of operation, that LEFM reverts to the Check mode (also described in this LAR as the Maintenance mode). The flow data from an LEFM with a single functioning plane (Check mode) has greater associated measurement uncertainty than that from an LEFM with both planes functioning, but less associated measurement uncertainty than that from a FW flow nozzle.

Conditions for operation, required actions, and completion times for the LEFM system are currently contained in TRM Section 3.20, Leading Edge Flow Meter (LEFM) System. In accordance with PBAPS Updated Final Safety Analysis Report (UFSAR), Section 13.6.8, Requirements Relocated Out of Technical Specifications, the TRM is a licensee-controlled procedure described in the UFSAR and therefore, changes to the TRM are subject to the requirements of 10 CFR 50.59, Changes, tests, and experiments. As such, changes to the LEFM TRM are controlled under the provisions of 10 CFR 50.59.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 5 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes 2.2 Current LEFM Compensatory Measures The LEFM status is determined and reported by the LEFM System computer based upon the number of functional planes in the LEFM and the data quality. If one or more LEFMs go into the Check mode with none in Fail mode, operators must switch flow input to the CTP calculation from the LEFM(s) that are not in CheckPlus mode to the associated calibrated FW flow nozzle within two hours. By the end of the 72-hour TRM Required Compensatory Measures Completion Time, either all LEFMs must be restored to the CheckPlus mode with all flow input to the CTP calculation from the LEFMs or MAPL must be reduced to 4010 MWt.

If one or more LEFM FW flow nozzle(s) reverts to the Fail mode or is not providing flow input to the CTP calculation, flow measurement from that FW line must be transferred to its calibrated FW flow nozzle within two hours. A FW flow nozzle is considered calibrated when a venturi correction factor (VCF) is applied to the FW flow nozzle measurement in accordance with station procedures. The VCF is the ratio of the flow measurement from the LEFM in CheckPlus mode to that of the associated FW flow nozzle. Under the current requirements, power must then be reduced to the pre-MUR level of 3951 MWt before the end of the 72-hour TRM Required Compensatory Measures Completion Time if all of the LEFMs have not been restored to either the CheckPlus or Check mode.

If an LEFM changes to a status other than CheckPlus after a TRM condition has been entered for that LEFM (i.e., mode status changes from Check to Fail or Fail to Check),

then the completion times for the new required compensatory measures of the applicable TRM condition(s) must be completed based on a start time corresponding to initial entry into the TRM condition.

As stated above, repair of an LEFM that degrades to the Maintenance or Fail mode may have to be delayed until the next refueling outage or require an unscheduled plant shutdown due to the high radiation levels during power operation in the vicinity of the spool pieces containing the flow measurement transducers and cabling.

2.3 Proposed Changes to the LEFM Compensatory Measures for LEFMs in Check The proposed changes would expand the number of intermediate power levels from one to four. The intermediate power levels correspond to the total power uncertainties (TPUs) conservatively calculated for each of the LEFM system meter conditions. The existing LEFM System TRM Section 3.20 would be revised to include the proposed changes to the Conditions, Required Compensatory Measures and Completion Times. Except for the specific LEFM condition and the interim power levels, the TRM actions and completion times are the same as currently contained in the NRC approved TRM. The LEFM status and proposed maximum interim power levels are described below:

1. Three separate intermediate power levels for the LEFM system meter conditions in which one, two, or three LEFMs are in Maintenance mode, with none in Fail mode.

2. A fourth intermediate power level is for one LEFM in the Fail mode with the other two LEFMs in Normal or Maintenance mode. The FW line FW flow nozzle is then used for the LEFM in Fail mode as the input to the core thermal power calculation.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 6 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes 2.4 Proposed Changes to the LEFM Compensatory Measures for One LEFM in Fail As with the current LEFM TRM Section 3.20 Required Compensatory Measures and Completion Times, the proposed changes in this LAR require that the FW flow signal from an LEFM that changes from CheckPlus to Check or Fail mode be switched to its associated calibrated FW flow nozzle within two hours.

As with the current LEFM TRM Section 3.20 Required Compensatory Measures and Completion Times, the proposed changes in this LAR require that, when one or more LEFMs are in Check mode with none in Fail mode by the end of the TRM Required Compensatory Measures Completion Time, flow input to the CTP calculation must be switched back to the LEFM and power reduced to the prescribed MAPL. For this LAR, two interim power levels are proposed for one and two LEFMs in the Check Mode based on the TPU for that condition as shown in the table below.

If one LEFM goes into Fail mode or is otherwise not providing flow input to the CTP calculation, and has not been restored to CheckPlus or Check mode by the end of the TRM Required Compensatory Measures Completion Time, power must be reduced to the MAPL commensurate with the TPU for the one LEFM in Fail mode condition shown in the table. If the affected LEFM is restored to the Check mode, power must be reduced to the MAPL appropriate to the LEFM operating condition (i.e., one, two, or three in Check mode with none in Fail mode) shown in the table below.

If this LAR is approved, the MAPLs for the various LEFM operating conditions shown in the table below will be incorporated into a revision to TRM Section 3.20 as provided in Attachment 2.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 7 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes LEFM OPERATING CONDITION TPU MAPL (MWt) Existing or New TRM Condition All LEFMs in CheckPlus mode 0.34% 4016 Existing One LEFM in Check mode; none in Fail 0.37% 4015 New mode Two LEFMs in Check mode; none in 0.43% 4012 New Fail mode Three LEFMs in Check mode 0.51% 4009 New One LEFM in Fail mode with the other 1.19% 3982 New two LEFMs in CheckPlus or Check mode, flow measurement by associated FW flow nozzle Two or three LEFMs in Fail mode 2%1 3951 Existing

3.0 TECHNICAL EVALUATION

3.1 Background PBAPS Units 2 and 3 have received the following license amendments authorizing increases in licensed CTP:

In 1994 and 1995, Amendments 198 and 211 to the Units 2 and 3 operating licenses, respectively, authorized a stretch power uprate of 5% from OLTP of 3293 MWt to 3458 MWt

In 2002, Amendments 247 and 250 to the Units 2 and 3 operating licenses, respectively, authorized an MUR uprate from 3458 MWt to 3514 MWt based on the reduced uncertainty in feedwater flow measurement using the installed LEFM systems (Reference 3).

In 2014, Amendments 293 and 296 to the Units 2 and 3 RFOLs authorized an EPU increasing power from 3514 MWt to 3951 MWt (Reference 4).

In 2017, Amendments 316 and 319 to the Units 2 and 3 RFOLs, respectively, authorized an MUR uprate from 3951 MWt to 4016 MWt based on the reduced uncertainty in feedwater flow measurement using the installed LEFM systems (Reference 2).

1 To comply with 10 CFR 50 Appendix K analysis.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 8 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes 3.2 General Approach The uncertainties associated with the LEFM operating conditions shown above are calculated as follows:

The uncertainty calculated for the condition in which feedwater flow on one of the three feedwater lines is being measured by the FW flow nozzle conservatively assumes that the LEFMs on the other two feedwater lines are in Check mode.

Calculation of the feedwater mass flow uncertainty for a line being measured by the FW flow nozzle assumes that the instrument loop has not been calibrated by the LEFM (i.e., VCF = 1.000).

The methodology used to calculate the loop uncertainty for the FW flow nozzle is based on EGC-accepted PBAPS plant setpoint methodology. In accordance with this methodology, independent error terms are combined via square root sum of the squares (SRSS) and taken to 2 or a 95% confidence level. Dependent errors are combined according to their dependency relationships and the biases algebraically summed. ASME PTC-6 (Reference 11) is used to determine the error in the FW flow nozzles because it provides a conservative means to quantify the FW flow nozzle uncertainties, and it takes into account the upstream and downstream flow disturbances due to piping configurations.

The methodology for the calculation of the feedwater mass flow uncertainty as measured by an LEFM in Check mode is the same as that performed for the MUR LAR (Reference 1) and is consistent with the methodology of Cameron Topical Report ER-157P-A Revision 8 (Reference 5).

Where PBAPS Units 2 and 3 plant specific data is used, the most conservative value from each Unit is used in the Uncertainty Analysis for thermal power determination.

The total feedwater mass flow uncertainty is calculated by combining the results for the LEFM and the FW flow nozzle uncertainties as appropriate for each LEFM operating condition using SRSS methodology consistent with ER-157P-A Revision 8.

The TPU for each LEFM operating condition is calculated by combining the feedwater mass flow uncertainty with other plant specific terms (steam enthalpy, moisture carryover, etc.) using SRSS methodology consistent with ER-157P-A Revision 8.

The TPU calculation (Attachment 4) differs from the methodology described in Cameron Topical Report ER-157P-A Revision 8 (Reference 5) only for the LEFM operating condition in which the flow input to the CTP for one of the FW lines is being measured by the FW flow nozzle.

The inputs and assumptions for the TPU calculation for the LEFM System condition of three LEFMs in the Check Mode are the same as those used in the TPU calculation for the MUR LAR submitted in 2017 (Reference 1, Attachment 8, Appendix B-1), except for the Time Measurement, Item 8, Non-Fluid Delay (Refer to this LAR Attachment 4, Appendix B-2). This uncertainty parameter increased slightly (i.e., from 0.50% to 0.51%)

due to a change that corrected an error in the previous revision of the uncertainty

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 9 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes calculation. The total uncertainty in the time spent by ultrasonic pulses in a non-fluid media for a single meter is made up of a random component and a systematic component that are root sum squared together (Refer to Reference 1 Attachment 8 Appendix A.5 and this LAR Attachment 4, Appendix A.5). When calculating the impact across multiple meters, the random portion of the term is divided by the square root of the number of meters (i.e., for PBAPS = sqrt(3)) because not only is it random within the meter, but also between meters. The effect of the systematic term though cannot be decreased in this manner and should remain constant even when considering multiple loops. The earlier LEFM calculation (Reference 1 Attachment 8, Appendix B-1) combined both the random and systematic terms and then divided that value by the sqrt(3) incorrectly. This has been corrected in the calculations provided in this LAR (Attachment 4, Appendix B-2).

Using the corrected Time Measurement values and the resulting TPU for three LEFMs in Check mode, the MAPL limit for TRM Required Compensatory Measure calculated value slightly decreased and due to rounding for conservatism, the proposed TRM MAPL limit is lowered from 4010 MWt to 4009 MWt. The Time Measurement parameter change is also used in the TPU calculations for the other LEFM system conditions described in this LAR. This correction was evaluated for impact on current LEFM TRM Required Compensatory Measure actions and appropriate corrective actions have been taken.

3.3 Plant Implementation The revised compensatory measures will be incorporated into the existing TRM Section 3.20. Only minor changes to other existing procedures will be required. A description of the impact of the implementation of the proposed change with respect to operator decision making and conservative plant operation is provided in Section 3.4 Criterion 1 below.

3.4 Disposition of NRC Criteria for Use of LEFM Topical Reports Attachment 1 to the MUR LAR (Reference 1) described how the nine criteria established by the NRC in References 7, 8 and 9 for licensees incorporating the LEFM methodology into the licensing basis are satisfied. The NRC approved this request in Amendments 316 and 319 (Reference 2) and specifically discussed in SER Section 3.5.4, Thermal Power Measurement Uncertainty. The paragraphs below confirm or update the disposition of these criteria at PBAPS as necessary for LEFM system conditions in which either one, two, or three LEFMs are in Check mode; and for the condition in which the FW flow input from one FW line to the CTP calculation is based on the associated FW flow nozzle.

Criterion 1 Discuss maintenance and calibration procedures that will be implemented with the incorporation of the LEFM, including processes and contingencies for inoperable LEFM instrumentation and the effect on thermal power measurements and plant operation.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 10 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes Response to Criterion 1 Calibration and Maintenance The proposed changes will not affect the calibration and maintenance procedures as described in the MUR LAR (Reference 1) for the LEFM system.

With respect to flow measurement by the FW flow nozzle, existing procedures require the calibration of the FW flow nozzle instrument loop every refueling outage. If measurement of FW flow is transferred from an LEFM to the FW flow nozzle, VCF is applied to the FW flow nozzle measurement. The VCF is based on inputs obtained within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from the time that the LEFM went into Check or Fail mode, or was otherwise removed from service. Operators in the main control room can assess the VCF displayed value which is updated continuously on the Plant Monitoring System (PMS) display. PBAPS Engineering performs a periodic comparison of the VCF value to established trends.

These measures will ensure the accuracy of the CTP calculation while relying on feedwater flow measurement from the FW flow nozzle.

LEFM Inoperability The disposition of Criterion 1, LEFM Inoperability contained in the MUR LAR is not changed by this LAR with the exception of the discussion of TRM Section 3.20 (5th paragraph of corresponding section in the MUR LAR) which is replaced by the discussion below.

As described in the following sections, the proposed changes to the compensatory measures requested in this LAR are consistent with the principles of simple decision making on the part of the control room operator and conservative plant operation.

Simple Decision Making The range of decisions and actions facing the operator will not be fundamentally different or made more complex by the proposed changes than those on which PBAPS operators have been trained on and implemented since the LEFM system was commissioned in 2002. On-line, continuous monitoring of system parameters generates PMS alarms in the control room that immediately alert the operator to a change in status of an LEFM.

The operators then execute existing procedure steps to calibrate the FW flow nozzle and switch the CTP calculation input to the FW flow nozzle. Then, if the LEFM is not restored to NORMAL status, the operators must reduce power by 1 to 34 MWt, depending on the LEFM malfunction, by lowering reactor recirculation flow within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the initial failure. Additionally, for an LEFM retained in the Maintenance mode, operators must re-align the associated FW flow nozzle measurement input to the plant CTP calculation back to the LEFM by the end of the 72-hour TRM Completion Time period using similar PMS computer input actions.

If for some reason it is not possible to calibrate the FW flow nozzle to its associated LEFM (e.g., a valid Venturi Correction Factor cannot be obtained), the proposed Required Compensatory Measures B.1.1, D.1.1, and F.1 require that power be reduced to a level supported by the uncertainty analysis after two hours. These power levels are specified in TRM Table 3.20-1 for LEFM(s) in the Check mode, or directly in the Compensatory Measures for an LEFM in the Fail mode. Operators would reduce reactor

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 11 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes power by lowering reactor recirculation flow using existing reactor power control procedure actions. Operator actions per this TRM are consistent with existing TS actions.

There are no new alarms or operator actions and no changes to operator response times introduced due to this TRM change. A minor revision to existing operating procedures will be made to reflect the new intermediate power levels. Swapping CTP inputs between the LEFM and the FW flow nozzle is a task performed several times a year using a procedure that has been in place since the installation of the LEFMs in 2002.

Because the proposed revision to TRM 3.20 has only a minor impact on existing operating procedures by adding intermediate power levels for when LEFM(s) enter non-Normal statuses, the revision will only have a minor impact on human factors in the areas of human performance and operator training. No additional training (apart from normal training for plant procedure changes) is required to operate the plant due to this TRM revision. The actions for communicating the TRM and procedure changes to the operators will be tracked using the existing Exelon configuration change control process.

A Human Factors Engineering (HFE) evaluation was performed using the guidance in NUREG 1764, Guidance for the Review of Changes to Human Actions, Revision 1. The HFE determined the following key conclusions:

Operator actions as they relate to monitoring reactor power via the calorimetric heat balance are not risk significant.

All operator actions including monitoring, adjusting CTP input parameters, and reducing power as required, have a high probability of success and do not result in the likelihood of undiscovered failures.

None of the operator actions required by the proposed change are included in Appendix A of NUREG-1764 Revision 1 as Generic Human Actions that are Risk-Important for BWRs.

The proposal does not change operator actions on systems that are of high or moderate risk-importance.

No changes are involved with the proposed LAR that would require additional reviews for Personnel Functions and Tasks, Design Support for Task Performance or Performance Shaping Factors.

The proposed TRM change only needs a Level III HFE review.

The control room operator therefore faces a simple set of criteria in deciding what actions to take for an inoperable LEFM, has adequate time to take such actions, and will use existing procedures that have been in place for a substantial period of time.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 12 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes Conservative plant operation Conservative plant operation under the new proposed compensatory measures starts with the calculations of the LEFM, FW flow nozzle and total power uncertainties on which the proposed changes to the LEFM system compensatory measures are based. Use of NRC-approved and industry-accepted methodologies and conservative assumptions will provide margin to ensure that the plants will not operate above the licensed thermal power. Plant monitoring instrumentation and procedures will verify that the assumptions underlying the uncertainty calculations remain valid.

The calculations of LEFM uncertainty use the same methodology as in the MUR LAR and are consistent with ER-157P-A Revision 8. Since there is some variation in the calculated LEFM uncertainties for each unit, the uncertainty values from the most limiting meter are applied to all of the LEFM meters. Another element of the conservatism in the LEFM uncertainty calculation is in the assumption made for plane balance variability (PBV). Plane balance refers to the ratio of the FW flow velocities as measured by each of the two planes of transducers in an LEFM CheckPlus system. Uncentered vortex and axial motions known as swirl can cause cross velocities which affect the accuracy of the measurement of feedwater mass flow from each plane and thereby change the plane balance. When operating in the CheckPlus mode, the LEFM flow measurement system will, by design, cancel out the cross velocities impacting each plane and they therefore do not contribute uncertainty to flow measurement. However, during operation in the Check mode, with only one plane of transducers, the uncancelled cross velocities must be considered in the determination of the LEFM uncertainty. Although recent plant-specific operating data indicates an uncertainty attributed to PBV of only 0.19% at a 2 confidence level, the LEFM uncertainty calculations supporting this LAR (Attachment 4) which, as stated above are the same as those approved by the NRC for the MUR LAR, apply a PBV uncertainty of 0.35%.

The calculation of the flow measurement error for the FW flow nozzle (Attachment 3) uses the ASME PTC-6 Report 1985 (Reference 11) methodology to determine the error in the FW flow nozzle, including upstream and downstream disturbances. FW flow nozzle instrument loop uncertainty is based on EGC setpoint methodology in which independent error terms are combined via SRSS and taken to a 2 or a 95% confidence level, and dependent errors are combined according to their dependency relationships and biases algebraically summed. The calculation for FW mass flow uncertainty as measured by the FW flow nozzle also assumes that it has not been calibrated to its associated LEFM which assumes a conservative uncertainty as further discussed below.

The TPU calculations which combine the LEFM and FW flow nozzle measurement uncertainties for each of the four intermediate MAPL limits also account for other plant-specific terms along with the FW mass flow uncertainty and combine these terms using SRSS methodology of ASME PTC 19.1 (Reference 10) consistent with ER-157P-A Revision 8.

The accuracy of CTP measurement with flow input from one FW flow nozzle can be maintained indefinitely, if necessary. The feedwater flow process is calibrated every refueling outage. Changes in FW flow nozzle differential pressure for a particular flow are usually due to fouling or erosion which occur over long periods. LEFM to FW flow nozzle measurement ratios are constantly updated in the plant process computer and nightly checks are made to ensure predetermined limits are not exceeded. Any slight drift of the FW flow nozzle measurements while operating at the proposed new intermediate point

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 13 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes due to FW flow nozzle fouling would result in a higher than actual indication of feedwater flow and an overestimation of the calculated calorimetric power level. A sudden de-fouling event while on the FW flow nozzle is unlikely and any significant sudden de-fouling would be detected by other plant parameters.

Criterion 2 For plants that currently have LEFMs installed, provide an evaluation of the operational and maintenance history of the installed installation and confirmation that the installed instrumentation is representative of the LEFM system and bounds the analysis and assumptions set forth in Topical Report ER-80P.

Response to Criterion 2 As stated in the MUR LAR, the PBAPS LEFM system installed instrumentation is representative of and bounded by the analysis and assumptions set forth in Topical Report ER-80P (Reference 6).

A review of the maintenance history of the LEFM system since January 2011 indicates the LEFM system continues to be highly reliable. During the period, no LEFMs were in the Fail mode. The LEFM system continued to be used for the FW flow measurement input but the improved uncertainty was not used between implementation of the EPU and MUR amendments. TRM actions for degraded LEFMs were re-instituted with implementation of the MUR amendment in January 2018. Since implementation of the MUR amendments, there were no instances on Unit 3 and one instance on Unit 2 when an LEFM was in the Check mode requiring MAPL reduction. In this instance, Unit 2 power was reduced to 4010 MWt in accordance with the TRM requirements. The Unit 2, Meter 1 transducer coupling has become degraded and has resulted in this LEFM entering the Check mode several times for short periods of time. A forced outage is required to troubleshoot and repair this LEFM.

EGC continues to follow an LEFM system preventive maintenance program based on vendor recommendations, industry lessons learned and performance data reviews.

Transducers and LEFM electronics are replaced as determined to be necessary by a review of the equipments operational history by the LEFM system vendor.

Criterion 3 Confirm that the methodology used to calculate the uncertainty of the LEFM in comparison to the current feedwater instrumentation is based on the accepted plant setpoint methodology (with regard to the development of instrument uncertainty). If an alternative approach is used, the application should be justified and applied to both venturi and ultrasonic flow measurement instrumentation installations for comparison.

Response to Criterion 3 The LEFM system uncertainty calculation methodology continues to be based on EGC-accepted PBAPS plant setpoint methodology as described in Attachment 1 to the MUR LAR. The calculation of the FW flow nozzle uncertainty is also based on EGC-accepted PBAPS plant setpoint methodology.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 14 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes The methodology for combining the FW flow nozzle and LEFM uncertainties to determine the total mass flow uncertainty, and then combining this with other plant-specific parameters (steam enthalpy, moisture carry-over, etc.) to calculate the TPU is based on the methodology described in the ASME PTC 19.1 methodology (Reference 10).

Criterion 4 For plants where the ultrasonic meter (including LEFM) was not installed with flow elements calibrated to a site-specific piping configuration (i.e., flow profiles and meter factors not representative of the plant specific installation), additional justification should be provided for its use. The justification should show that the meter installation is either independent of the plant specific flow profile for the stated accuracy, or that the installation can be shown to be equivalent to known calibrations and plant configurations for the specific installation including the propagation of flow profile effects at higher Reynolds numbers. Additionally, for previously installed calibrated elements, confirm that the piping configuration remains bounding for the original LEFM installation and calibration assumptions.

Response to Criterion 4 Disposition of this Criterion is not changed by this LAR from that provided in Attachment 1 to the MUR LAR as reviewed and approved by the NRC.

Criterion 5 Justification for continued operation at the pre-failure level for a pre-determined time and the decrease in power that must occur following that time are plant-specific and must be acceptably justified.

Response to Criterion 5 Justification for continued operation at 4016 MWt for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with one or more LEFMs either in Fail or in Check mode is not changed from that provided in Attachment 1 to the MUR LAR as reviewed and approved by the NRC.

Justification for the required decreases in power by the end of the TRM Required Compensatory Measures Completion Time for each of the proposed intermediate LEFM conditions is provided in the response to Criterion 1 above.

Criterion 6 A CheckPlus operating with a single failure is not the same as an LEFM Check. Although the effect on hydraulic behavior is expected to be negligible, this must be acceptably quantified if a licensee wishes to operate using the degraded CheckPlus at a degraded uncertainty.

Response to Criterion 6 Disposition of this Criterion is not changed by this LAR from that provided in Attachment 1 to the MUR LAR as reviewed and approved by the NRC (Reference 2).

Criterion 7 An applicant with a comparable geometry can reference the above Section 3.2.1 finding

[of the Final NRC Safety Evaluation for Caldon Topical Report ER-157P Rev 8] to support a conclusion that downstream geometry does not have a significant influence on CheckPlus calibration. However, CheckPlus results do not apply to a Check and downstream effects with use of a CheckPlus with disabled components that make the

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 15 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes CheckPlus comparable to a Check must be addressed. An acceptable method is to conduct applicable Alden Laboratory tests.

Response to Criterion 7 Disposition of this Criterion is not changed by this LAR from that provided in Attachment 1 to the MUR LAR as reviewed and approved by the NRC (Reference 2).

Criterion 8 An applicant that requests an MUR with the upstream flow straightener configuration discussed in Section 3.2.2 [of the Final NRC Safety Evaluation for Caldon Topical Report ER-157P Rev 8] should provide justification for claimed CheckPlus uncertainty that extends the justification provided in Reference 17. Since the Reference 17 evaluation does not apply to the Check, a comparable evaluation must be accomplished if a Check is to be installed downstream of a tubular flow straightener.

Response to Criterion 8 Disposition of this Criterion is not changed by this LAR from that provided in Attachment 1 to the MUR LAR as reviewed and approved by the NRC (Reference 2).

Criterion 9 An applicant assuming large uncertainties in steam moisture content should have an engineering basis for the distribution of uncertainties or, alternatively, should ensure that their calculations provide margin sufficient to cover the differences shown in Figure 1 of Reference 18.

Response to Criterion 9 Disposition of this Criterion is not changed by this LAR from that provided in Attachment 1 to the MUR LAR as reviewed and approved by the NRC (Reference 2).

3.5 Deficiencies and Corrective Actions The handling of any problems, performance or reliability issues with the LEFMs as reported in the MUR LAR is not changed by this LAR. Problems with plant instrumentation, including the LEFM system and FW flow nozzles are documented in the PBAPS corrective action program and necessary corrective actions are identified and implemented. Deficiencies associated with the vendors processes or equipment are reported to the vendor to support corrective action.

3.6 Reactor Power Monitoring PBAPS Unit 2 and Unit 3 have procedures that provide guidance for monitoring and controlling reactor power and ensuring that reactor power remains within the requirements of the operating license.

4.0 ADDITIONAL CONSIDERATIONS 4.1 Plant Modifications No plant modifications are required.

4.2 Operator Training, Human Factors, and Procedures

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 16 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes Implementation of this LAR would only have a minor impact on human factors in the areas of operating procedure changes, operator training and operator human performance. Existing procedures will be modified to reflect the revised TRM Section 3.20 (Attachment 2). There are no changes to the control room, indications, alarms, computer displays or the simulator necessary to implement this LAR. Operators will be trained on implementation of the revised TRM Section 3.20 requirements in accordance with the PBAPS Licensed Operator Training program before implementation. The actions for communicating the TRM and procedure changes to the operators will be tracked using the existing EGC configuration change control process.

As discussed in Section 3.4 under Criterion 1, the proposed change will not impose any complex decision making requirements on the operators and only Level III HFE review is warranted.

4.3 Testing No additional testing is necessary for implementation of this LAR.

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria 10 CFR 50, Appendix K, ECCS Evaluation Models, requires that emergency core cooling system evaluation models assume that the reactor has been operating continuously at a power level at least 1.02 times the licensed power level to allow for instrumentation error. A change to this paragraph, which became effective on July 1, 2000, allows a lower assumed power level, provided the proposed value has been demonstrated to account for uncertainties due to power level instrumentation error.

The NRC issued a safety evaluation report (Reference 2) on the license amendment request (LAR) submitted by Exelon Generating Company, LLC (EGC) for a Measurement Uncertainty Recapture Power Uprate (Reference 1) and amended the PBAPS Units 2 and 3 operating licenses to allow an increase in maximum licensed thermal power based on a lower calculated uncertainty associated with the measurement of the feedwater flow input to the core thermal power (CTP) calculation from the LEFM system.

This application for a LAR approval is for a change to the compensatory measures for degraded LEFM conditions. The proposed changes would allow operation at power levels commensurate with the uncertainties in the measurement of CTP as calculated in Attachments 3 and 4 for conditions in which the flow from either one, two or three feedwater (FW) lines is being measured by LEFMs that have degraded from the CheckPlus to the Check mode with none in Fail mode as well as when one LEFM is in Fail mode or not providing flow input to CTP, with flow measurement provided by the associated FW flow nozzle.

This application is consistent with the requirements and criteria described in 10 CFR 50, Appendix K and 10 CFR 50.90.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 17 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes 5.2 Precedent The NRC has approved an intermediate power level for a Check (Maintenance) mode for the following plants:

PLANT LAR Accession No. NRC SER Accession No.

PBAPS 2&3 ML17048A444 ML17286A013 Columbia ML16183A365 ML17095A117 Turkey Point 3&4 ML103610319 ML11293A359 St. Lucie 1 ML103560429 ML12191A220 St. Lucie 2 ML110730341 ML12235A463 Shearon Harris ML11356A096 ML11124A180 Prairie Island ML093650061 ML102030573 In the Turkey Point and St. Lucie 1 and 2 safety evaluation reports, the NRC discussed simple decision making and conservative plant operation in the evaluation of the MUR requests. The PBAPS demonstration of compliance with these criteria is provided above in Section 3.4 in the response to Criterion 1.

5.3 No Significant Hazards Consideration The NRC approved a license amendment request (LAR) by Exelon Generation Company, LLC (EGC) for a Measurement Uncertainty Recapture Power Uprate (Reference 1) and authorized an increase of 65 megawatts in maximum licensed thermal power from 3951 megawatts thermal (MWt) to 4016 MWt in Amendments 316 and 319 to the Peach Bottom Atomic Power Station (PBAPS) Unit 2 and Unit 3 Renewed Facility Operating License (RFOL), respectively. The approved license amendments were based on the increased accuracy of the Cameron Holding Corporation (hereinafter Cameron) +

(CheckPlus) Leading Edge Flow Meter (LEFM) ultrasonic flow measurement instrumentation relative to the feedwater (FW) flow nozzle (venturi meter) differential pressure measurement installed at PBAPS in the calculation of core thermal power (CTP).

In accordance with 10 CFR 50.90, Application for Amendment of License, Construction Permit, or Early Site Permit, EGC is proposing that RFOL Nos. DPR 44 and DPR-56 for PBAPS Units 2 and 3, respectively, be amended to allow operation at power levels based on the uncertainties calculated for the measurement of CTP when either one, two or three LEFMs are operable but in a degraded condition (Check mode) with none inoperable; and when one LEFM is inoperable (Fail mode) or the flow input to the CTP calculation for one of the FW lines is from the associated FW flow nozzle. EGC has evaluated whether a significant hazards consideration is involved with the proposed changes in accordance with the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below.

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 18 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes Response: No, the proposed change does not significantly increase the probability or consequences of an accident previously evaluated.

The proposed change does not affect system design or operation and thus does not create any new accident initiators or increase the probability of an accident previously evaluated. Accident mitigation systems are not affected and will function as designed.

The proposed change does not increase the licensed thermal power level and will not cause the thermal power level at which the Emergency Core Cooling Systems have been analyzed in accordance with Appendix K to 10 CFR 50 to be exceeded. All safety analyses continue to be bounded by the safety analyses for the current licensed thermal power.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of operation at power levels based on the uncertainties in the calculation of CTP for the stated LEFM system conditions. Calculation of the uncertainty associated with these plant conditions as well as existing plant instrumentation and procedures ensure that the licensed thermal power and the thermal power level at which the Emergency Core Cooling Systems have been analyzed in accordance with Appendix K to 10 CFR 50 will not be exceeded. No new equipment or procedure changes are involved that could add new accident initiators.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No, the proposed change does not involve a significant reduction in a margin of safety.

Operation at power levels based on the uncertainties in the calculation of CTP for the stated LEFM system conditions does not involve a significant reduction in a margin of safety. Calculation of the uncertainties associated with the measurement of core thermal power for these plant conditions as well as existing plant instrumentation and procedures ensure that the licensed thermal power and the thermal power level at which the Emergency Core Cooling Systems have been analyzed in accordance with Appendix K to 10 CFR 50 will not be exceeded.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 19 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes Therefore, the proposed change does not involve a significant reduction in a margin of safety.

5.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.

Based on the above evaluation, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and accordingly, a finding of no significant hazards consideration is justified.

6.0 ENVIRONMENTAL CONSIDERATION

10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusions or otherwise not requiring environmental review," addresses requirements for submitting environmental assessments as part of licensing actions. 10 CFR 51.22, paragraph (c)(9) states that a categorical exclusion applies for Part 50 license amendments that meet the following criteria:

i. No significant hazards consideration (as defined in 10 CFR 50.92(c));

ii. No significant change in the types or significant increase in the amounts of any effluents that may be released offsite; and iii. No significant increase in individual or cumulative occupational radiation exposure.

The proposed change does not involve a significant hazards consideration. No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed change. Operation in accordance with the proposed license amendments will not involve a significant reduction in a margin of safety.

No significant changes in types or amounts of effluents released into the environment will occur as a result of the proposed change. The Pennsylvania Department of Environmental Protection (PDEP) National Pollutant Discharge Elimination System (NPDES) permit provides the effluent limitations and monitoring requirements for wastewater at the site.

There is no significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

License Amendment Request Attachment 1 Expanded Actions for LEFM Conditions Page 20 of 20 Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes

7.0 REFERENCES

1. Exelon letter to NRC, Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate, dated February 17, 2017 (ADAMS Accession No. ML17048A444)

2. NRC letter to Exelon, Peach Bottom Atomic Power Station, Units and 3 - Issuance of License Amendment Re: Measurement Uncertainty Recapture Power Uprate dated November 15, 2017 (ML17286A013)

3. Letter from NRC to John L. Skolds, Peach Bottom Atomic Power Station, Units 2 And 3

- Issuance of Amendment Re: 1.62% Increase In Licensed Power Level (TAC Nos.

MB5192 and MB5193), dated November 22, 2002

4. NRC letter to Exelon, Peach Bottom Atomic Power Station, Units and 3 - Issuance of License Amendment Re: Extended Power Uprate, (TAC Nos. ME9631 and ME9632),

dated August 14, 2014 (Accession No. ML14133A046)

5. Caldon (now Cameron) Topical Report ER-157P-A, Supplement to Caldon Topical Report ER-80P: Basis for Power Uprates with an LEFM TM or an LEFM CheckPlus TM System, Rev. 8, dated May 2008

6. Caldon (now Cameron) Topical Report ER-80P, Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM + System, Rev 0 dated March 1997

7. NRC letter to Florida Power and Light Company, Turkey Point Units 3 and 4 - Issuance of Amendments Regarding Extended Power Uprate, dated June 15, 2012 (ML11293A365)

8. NRC letter to Florida Power and Light Company, St. Lucie Plant, Unit 1 - Issuance of Amendments Regarding Extended Power Uprate, dated July 9, 2012 (ML12191A220)

9. NRC letter to Florida Power and Light Company, St. Lucie Plant, Unit 2 - Issuance of Amendments Regarding Extended Power Uprate, dated September 24, 2012 (ML12235A463)

10. ASME PTC 19.1-1998, Test Uncertainty, Instruments and Apparatus, American Society of Mechanical Engineers, 1998

11. ANSI/ASME PTC-6 Report 1985, Guidance for the Evaluation of Measurement Uncertainty in Performance Tests of Steam Turbines

12. Exelon letter to NRC, Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate - Supplement 1 - Request for Non-Proprietary Version of Cameron Corporation Proprietary Documents, dated March 20, 2017 (ADAMS Accession No. ML17080A067)

ATTACHMENT 2 License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 License Amendment Request - Expanded Actions for LEFM Conditions Markup of Proposed Technical Requirements Manual and Bases Pages (For Information Only)

Unit 2 Unit 3 3.20-1 3.20-1 3.20-2 3.20-2 3.20-3 3.20-3 3.20-4 3.20-4 B 3.20-1 B 3.20-1 B 3.20-2 B 3.20-2 B 3.20-3 B 3.20-3

Leading Edge Flow Meter (LEFM) System 3.20 3.20 LEADING EDGE FLOW METER (LEFM) SYSTEM TRMS 3.20 Three Leading Edge Flow Meters (LEFM) shall be NORMAL and providing flow input to Core Thermal Power calculation.

APPLICABILITY: MODE 1 with THERMAL POWER > 3951 MWt COMPENSATORY MEASURES

NOTE ----------------------------------------------------------

See Bases for Definitions of a Flow Meter in NORMAL, MAINTENANCE and FAIL status.

Separate Condition entry is allowed for each Flow Meter.

REQUIRED COMPENSATORY COMPLETION CONDITION MEASURE TIME A. One or more Flow Meters A.1 Replace flow input to the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in MAINTENANCE Core Thermal Power calculation from the affected Flow Meter with input from the associated calibrated feedwater flow nozzle.

AND A.2 Restore affected Flow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Meter to NORMAL and ensure it is providing flow input to the Core Thermal Power calculation.

PBAPS UNIT 2 3.20-1 Revision 4a

Leading Edge Flow Meter (LEFM) System 3.20 B. Required Compensatory B.1.1 Reduce MAPL to less Immediately Measure and associated than or equal to value Completion Time of listed in Condition A not met. Table 3.20-1.

AND Immediately B.1.2 Ensure flow input to the Core Thermal Power calculation is from the affected Flow Meter in MAINTENANCE.

OR Immediately B.2 Reduce MAPL to less than or equal to 3951 MWt C. One Flow Meter in FAIL or C.1 Replace flow input to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months not providing flow input to the Core Thermal the Core Thermal Power Power calculation calculation. from affected Flow Meter with input from the associated calibrated feedwater flow nozzle.

AND C.2 Restore affected 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Flow Meter to NORMAL and ensure it is providing flow input to the Core Thermal Power calculation.

PBAPS UNIT 2 3.20-2 Revision 4a

Leading Edge Flow Meter (LEFM) System 3.20 D. Required Compensatory D.1.1 Reduce MAPL to Immediately Measure and associated less than or equal to Completion Time of 3982 MWt.

Condition C not met.

AND D.1.2 Ensure flow input to Immediately the Core Thermal Power calculation is from the associated feedwater flow nozzle.

OR Immediately D.2 Reduce MAPL to less than or equal to 3951 MWt E. Two or more Flow E.1 Replace flow input 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Meters in FAIL or not to the Core Thermal providing flow input to Power calculation the Core Thermal Power from affected Flow calculation. Meters with input from the associated calibrated feedwater flow nozzles.

AND E.2 Restore affected 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Flow Meters to NORMAL and ensure they are providing flow input to the Core Thermal Power calculation.

PBAPS UNIT 2 3.20-3 Revision 4a

Leading Edge Flow Meter (LEFM) System 3.20 F. Required Compensatory F.1 Reduce MAPL to less Immediately Measure and associated than or equal to Completion Time of 3951 MWt.

Condition E not met.

LEFM TEST REQUIREMENTS TEST FREQUENCY TR 3.20.1 Perform CHANNEL CALIBRATION 24 months Table 3.20-1 Allowable MAPL for LEFM System Status LEFM System Status MAPL (MWt) 1 Flow Meter in MAINTENANCE, 2 in NORMAL 4015 2 Flow Meters in MAINTENANCE, 1 in NORMAL 4012 3 Flow Meters in MAINTENANCE, 0 in NORMAL 4009 PBAPS UNIT 2 3.20-4 Revision 4a

Leading Edge Flow Meter (LEFM) System B 3.20 B 3.20 LEADING EDGE FLOW METER (LEFM) SYSTEM BASES This TRMS is provided to ensure that Core Thermal Power (CTP) is maintained at a level consistent with the feedwater flow measurement uncertainty. The three LEFM System Flow Meters shall be NORMAL and providing flow input to the CTP calculation for power operations above 3951 MWt or CTP must be limited in accordance with this TRMS. This TRMS allows Separate Condition Entry for each LEFM System Flow Meter.

The LEFM System consists of three Flow Meters, one in each of the three feedwater lines. Each Flow Meter contains flow transducers arranged in two planes. Plane 1 consists of flow transducer paths 1 through 4 and Plane 2 consists of flow transducer paths 5 through 8. The flow data from a Flow Meter with a single functioning plane has greater associated measurement uncertainty than that from a Flow Meter with both planes functioning, but less associated measurement uncertainty than that from a feedwater flow nozzle (Venturi) , except within the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months following Venturi calibration. It has been demonstrated that Venturi-supplied flow data exhibits an insignificant deviation during this period following calibration by a Flow Meter with both planes functioning (see Reference 3). For this reason, following the loss of an LEFM plane, swapping flow input to the associated calibrated Venturi is preferable for the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and CTP is not required to be lowered during this time interval.

The LEFM System computer converts the Flow Meter data into feedwater flow and temperature signals for that loop, and provides a self-check via Plant Monitoring System computer alarms. There are three possible statuses for a Flow Meter:

NORMAL, MAINTENANCE, and FAIL.

A Flow Meter status is considered NORMAL IF:

The LEFM System Computer indicates that Flow Meter status (mode) to be Normal (also known as CheckPlus Mode).

A Flow Meter status is considered MAINTENANCE IF:

The LEFM System Computer indicates that Flow Meter status (mode) to be Maintenance (also known as Check Mode).

A Flow Meter status is considered FAIL IF:

The LEFM System Computer indicates that Flow Meter status (mode) to be Fail.

PBAPS UNIT 2 B 3.20-1 Revision 4a

Leading Edge Flow Meter (LEFM) System B 3.20 The Flow Meter status is determined and reported by the LEFM System computer based upon the number of functional planes in the Flow Meter and upon its data quality. For additional background information on the criteria used by the LEFM System computer to determine the status of an individual Flow Meter, see References 1 and 2.

When this TRMS is applicable (greater than 3951 MWt) and except as explicitly directed otherwise in the TRM, the feedwater flow input to the Core Thermal Power calculation from a Flow Meter that is not NORMAL is to be replaced with that from the associated calibrated feedwater flow nozzle (Venturi). A feedwater flow nozzle is calibrated when a correction factor based on the LEFM/Venturi ratio is applied to the feedwater flow nozzle measurement in accordance with station operating procedures.

This will ensure accuracy of the Core Thermal Power calculation while relying on the feedwater flow nozzle input to the Core Thermal Power calculation. See Reference 3.

The feedwater flow signal from a Flow Meter in FAIL status is to remain replaced by its corresponding feedwater flow nozzle as long as the Flow Meter remains in FAIL. In the case of a single Flow Meter in FAIL, Compensatory Measure D.1.1 allows for operation at an intermediate power level of 3982 MWt beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , since long-term feedwater flow nozzle instrument drift has been accounted for in the uncertainty analysis (Reference 4). Compensatory Measure D.1.2 does not require the flow nozzle to be calibrated by its associated LEFM since the additional uncertainty is encompassed by the lower intermediate power level.

The remaining two Flow Meters must remain in either NORMAL or MAINTENANCE status. If a second LEFM enters FAIL mode, Condition E applies and the completion time clocks for Compensatory Measures E.1 and E.2 immediately start.

The feedwater flowrate signal from a Flow Meter in MAINTENANCE status is to provide input to the Core Thermal Power calculation when operating at an intermediate power level specified in Table 3.20-1. These intermediate power levels are predicated upon all three feedwater flow inputs being provided by Flow Meters that are all in either NORMAL or MAINTENANCE status.

If all three Flow Meters are restored to the NORMAL status after entry into Required Compensatory Measure B.1, then all three Flow Meters must provide feedwater flow input to the Core Thermal Power calculation prior to raising power greater than the value specified in Table 3.20-1.

If the status of a Flow Meter changes to a status other than NORMAL after a TRM Condition has been entered for that Flow Meter (i.e., status from MAINTENANCE to FAIL or FAIL to MAINTENANCE), then the Completion Time(s) for the new Required Compensatory Measure(s) of the applicable TRM Condition(s) must be completed based upon a start time corresponding to initial entry into the TRM for the specific Flow Meter. The accuracy of the calibrated feedwater flow nozzle (Venturi) can only be credited for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months based on the insignificant instrument drift, see Reference 3. If PBAPS UNIT 2 B 3.20-2 Revision 4a

Leading Edge Flow Meter (LEFM) System B 3.20 the Flow Meter cannot be restored to NORMAL in the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time, then CTP must be lowered as directed by the appropriate Required Compensatory Measure based on Flow Meter status at the time.

The analysis supporting the allowable power levels provided in the TRM is contained in References 1 and 2.

The LEFM System and feedwater flow nozzle transmitter calibration are checked at regularly scheduled intervals. The frequency has been selected based on the reliability of the system. Additionally, parameters which input into the Core Thermal Power calculation are routinely validated to be within established bands.

CTP restrictions imposed by this TRM are controlled via plant procedures by changing the Maximum Allowable Power Level (MAPL). Changing the MAPL setting within the Plant Monitoring System computer ensures operation is within allowable limits.

REFERENCES:

1. Calculation PM-1201, Uncertainty Analysis for Thermal Power Determination at PB2 Using the LEFM CheckPlus System, VNDR DWG NUMBER ER464

2. Calculation PM-1202, Uncertainty Analysis for Thermal Power Determination at PB3 Using the LEFM CheckPlus System, VNDR DWG NUMBER ER463

3. Technical Evaluation 624827, LEFM SYSTEM POST-MUR LAR TECHNICAL EVALUATION

4. Calculation PM-1209, Peach Bottom Feedwater Flow Uncertainty in the Plant Computer as Measured by the Flow Nozzles Without Calibration by the LEFM PBAPS UNIT 2 B 3.20-3 Revision 4a

Leading Edge Flow Meter (LEFM) System 3.20 3.20 LEADING EDGE FLOW METER (LEFM) SYSTEM TRMS 3.20 Three Leading Edge Flow Meters (LEFM) shall be NORMAL and providing flow input to Core Thermal Power calculation.

APPLICABILITY: MODE 1 with THERMAL POWER > 3951 MWt COMPENSATORY MEASURES

NOTE ----------------------------------------------------------

See Bases for Definitions of a Flow Meter in NORMAL, MAINTENANCE and FAIL status.

Separate Condition entry is allowed for each Flow Meter.

REQUIRED COMPENSATORY COMPLETION CONDITION MEASURE TIME A. One or more Flow Meters A.1 Replace flow input to the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in MAINTENANCE Core Thermal Power calculation from the affected Flow Meter with input from the associated calibrated feedwater flow nozzle.

AND A.2 Restore affected Flow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Meter to NORMAL and ensure it is providing flow input to the Core Thermal Power calculation.

PBAPS UNIT 3 3.20-1 Revision 3a

Leading Edge Flow Meter (LEFM) System 3.20 B. Required Compensatory B.1.1 Reduce MAPL to less Immediately Measure and associated than or equal to value Completion Time of listed in Condition A not met. Table 3.20-1.

AND Immediately B.1.2 Ensure flow input to the Core Thermal Power calculation is from the affected Flow Meter in MAINTENANCE.

OR Immediately B.2 Reduce MAPL to less than or equal to 3951 MWt C. One Flow Meter in FAIL or C.1 Replace flow input to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months not providing flow input to the Core Thermal the Core Thermal Power Power calculation calculation. from affected Flow Meter with input from the associated calibrated feedwater flow nozzle.

AND C.2 Restore affected 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Flow Meter to NORMAL and ensure it is providing flow input to the Core Thermal Power calculation.

PBAPS UNIT 3 3.20-2 Revision 3a

Leading Edge Flow Meter (LEFM) System 3.20 D. Required Compensatory D.1.1 Reduce MAPL to Immediately Measure and associated less than or equal to Completion Time of 3982 MWt.

Condition C not met.

AND D.1.2 Ensure flow input to Immediately the Core Thermal Power calculation is from the associated feedwater flow nozzle.

OR Immediately D.2 Reduce MAPL to less than or equal to 3951 MWt E. Two or more Flow E.1 Replace flow input 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Meters in FAIL or not to the Core Thermal providing flow input to Power calculation the Core Thermal Power from affected Flow calculation. Meters with input from the associated calibrated feedwater flow nozzles.

AND E.2 Restore affected 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Flow Meters to NORMAL and ensure they are providing flow input to the Core Thermal Power calculation.

PBAPS UNIT 3 3.20-3 Revision 3a

Leading Edge Flow Meter (LEFM) System 3.20 F. Required Compensatory F.1 Reduce MAPL to less Immediately Measure and associated than or equal to Completion Time of 3951 MWt.

Condition E not met.

LEFM TEST REQUIREMENTS TEST FREQUENCY TR 3.20.1 Perform CHANNEL CALIBRATION 24 months Table 3.20-1 Allowable MAPL for LEFM System Status LEFM System Status MAPL (MWt) 1 Flow Meter in MAINTENANCE, 2 in NORMAL 4015 2 Flow Meters in MAINTENANCE, 1 in NORMAL 4012 3 Flow Meters in MAINTENANCE, 0 in NORMAL 4009 PBAPS UNIT 3 3.20-4 Revision 3a

Leading Edge Flow Meter (LEFM) System B 3.20 B 3.20 LEADING EDGE FLOW METER (LEFM) SYSTEM BASES This TRMS is provided to ensure that Core Thermal Power (CTP) is maintained at a level consistent with the feedwater flow measurement uncertainty. The three LEFM System Flow Meters shall be NORMAL and providing flow input to the CTP calculation for power operations above 3951 MWt or CTP must be limited in accordance with this TRMS. This TRMS allows Separate Condition Entry for each LEFM System Flow Meter.

The LEFM System consists of three Flow Meters, one in each of the three feedwater lines. Each Flow Meter contains flow transducers arranged in two planes. Plane 1 consists of flow transducer paths 1 through 4 and Plane 2 consists of flow transducer paths 5 through 8. The flow data from a Flow Meter with a single functioning plane has greater associated measurement uncertainty than that from a Flow Meter with both planes functioning, but less associated measurement uncertainty than that from a feedwater flow nozzle (Venturi), except within the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months following Venturi calibration. It has been demonstrated that Venturi-supplied flow data exhibits an insignificant deviation during this period following calibration by a Flow Meter with both planes functioning (see Reference 3). For this reason, following the loss of an LEFM plane, swapping flow input to the associated calibrated Venturi is preferable for the first 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and CTP is not required to be lowered during this time interval.

The LEFM System computer converts the Flow Meter data into feedwater flow and temperature signals for that loop, and provides a self-check via Plant Monitoring System computer alarms. There are three possible statuses for a Flow Meter:

NORMAL, MAINTENANCE, and FAIL.

A Flow Meter status is considered NORMAL IF:

The LEFM System Computer indicates that Flow Meter status (mode) to be Normal (also known as CheckPlus Mode).

A Flow Meter status is considered MAINTENANCE IF:

The LEFM System Computer indicates that Flow Meter status (mode) to be Maintenance (also known as Check Mode).

A Flow Meter status is considered FAIL IF:

The LEFM System Computer indicates that Flow Meter status (mode) to be Fail.

PBAPS UNIT 3 B 3.20-1 Revision 3a

Leading Edge Flow Meter (LEFM) System B 3.20 The Flow Meter status is determined and reported by the LEFM System computer based upon the number of functional planes in the Flow Meter and upon its data quality. For additional background information on the criteria used by the LEFM System computer to determine the status of an individual Flow Meter, see References 1 and 2.

When this TRMS is applicable (greater than 3951 MWt) and except as explicitly directed otherwise in the TRM, the feedwater flow input to the Core Thermal Power calculation from a Flow Meter that is not NORMAL is to be replaced with that from the associated calibrated feedwater flow nozzle (Venturi). A feedwater flow nozzle is calibrated when a correction factor based on the LEFM/Venturi ratio is applied to the feedwater flow nozzle measurement in accordance with station operating procedures.

This will ensure accuracy of the Core Thermal Power calculation while relying on the feedwater flow nozzle input to the Core Thermal Power calculation. See Reference 3.

The feedwater flow signal from a Flow Meter in FAIL status is to remain replaced by its corresponding feedwater flow nozzle as long as the Flow Meter remains in FAIL. In the case of a single Flow Meter in FAIL, Compensatory Measure D.1.1 allows for operation at an intermediate power level of 3982 MWt beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , since long-term feedwater flow nozzle instrument drift has been accounted for in the uncertainty analysis (Reference 4). Compensatory Measure D.1.2 does not require the flow nozzle to be calibrated by its associated LEFM since the additional uncertainty is encompassed by the lower intermediate power level.

The remaining two Flow Meters must remain in either NORMAL or MAINTENANCE status. If a second LEFM enters FAIL mode, Condition E applies and the completion time clocks for Compensatory Measures E.1 and E.2 immediately start.

The feedwater flowrate signal from a Flow Meter in MAINTENANCE status is to provide input to the Core Thermal Power calculation when operating at an intermediate power level specified in Table 3.20-1. These intermediate power levels are predicated upon all three feedwater flow inputs being provided by Flow Meters that are all in either NORMAL or MAINTENANCE status.

If all three Flow Meters are restored to the NORMAL status after entry into Required Compensatory Measure B.1, then all three Flow Meters must provide feedwater flow input to the Core Thermal Power calculation prior to raising power greater than the value specified in Table 3.20-1.

If the status of a Flow Meter changes to a status other than NORMAL after a TRM Condition has been entered for that Flow Meter (i.e., status from MAINTENANCE to FAIL or FAIL to MAINTENANCE), then the Completion Time(s) for the new Required Compensatory Measure(s) of the applicable TRM Condition(s) must be completed based upon a start time corresponding to initial entry into the TRM for the specific Flow Meter. The accuracy of the calibrated feedwater flow nozzle (Venturi) can only be credited for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months based on the insignificant instrument drift, see Reference 3. If PBAPS UNIT 3 B 3.20-2 Revision 3a

Leading Edge Flow Meter (LEFM) System B 3.20 the Flow Meter cannot be restored to NORMAL in the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time, then CTP must be lowered as directed by the appropriate Required Compensatory Measure based on Flow Meter status at the time.

The analysis supporting the allowable power levels provided in the TRM is contained in References 1 and 2.

The LEFM System and feedwater flow nozzle transmitter calibration are checked at regularly scheduled intervals. The frequency has been selected based on the reliability of the system. Additionally, parameters which input into the Core Thermal Power calculation are routinely validated to be within established bands.

CTP restrictions imposed by this TRM are controlled via plant procedures by changing the Maximum Allowable Power Level (MAPL). Changing the MAPL setting within the Plant Monitoring System computer ensures operation is within allowable limits.

REFERENCES:

1. Calculation PM-1201, Uncertainty Analysis for Thermal Power Determination at PB2 Using the LEFM CheckPlus System, VNDR DWG NUMBER ER464

2. Calculation PM-1202, Uncertainty Analysis for Thermal Power Determination at PB3 Using the LEFM CheckPlus System, VNDR DWG NUMBER ER463

3. Technical Evaluation 624827, LEFM SYSTEM POST-MUR LAR TECHNICAL EVALUATION

4. Calculation PM-1209, Peach Bottom Feedwater Flow Uncertainty in the Plant Computer as Measured by the Flow Nozzles Without Calibration by the LEFM PBAPS UNIT 3 B 3.20-3 Revision 3a

ATTACHMENT 3 License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 License Amendment Request - Expanded Actions for LEFM Conditions Exelon Calculation PM-1209 Revision 0, Peach Bottom Feedwater Flow Uncertainty as Measured in the Plant Computer as Measured by the Flow Nozzles Without Calibration by the LEFM

cc. AA-309 ..1001 Revision 9 ATTACHMENT 1

. De~ign Analysis Cover Sheet Pa e 1 Design Analysis I Last Page No.. 6 Attachment F page F2 Analysis No.: 1 PM-1209 . Revision: 2 000 Major l8I Minor D

Title:

3 Peach Bottom Feedwater Flow Uncertainty in the Plant Computer as Measured by the Flow Nozzles Without Calibration by the LEFM EC No.: 4 ~ 2. ( 3 Z 0 Revision: 5 0 7 14 Station(s): Peach Bottom Component(s):

8 2,3 Unit No.: See list in Section 1.0 Discipline: 9 PEDM 10 Descrip. Code/Keyword: N/A 11 Safety/QA Class: SR 12 System Code: 06 Structure: 13 N/A CONTROLLED DOCUMENT REFERENCES 15 Document No.: FromfTo Document No.: From/To EE-0029 From Is this Design Analysis Safeguards Information? 16 Yes 0 No 181 If yes, see SY-AA-101-106 Does this Design Analysts contain Unverified Assumptions? 17 Yes D No~ If yes, ATl/AR#:

This pesign Analysis SUPERCEDES: 18 NIA

t in its entirety.

Description of Revision {list changed pages when all pages of original analysis were not changed): 19 Initial issue.

Patricia A. Ugorcak Print Name B-2~-zat Date Method of Review: 21 Detailed Review 181 Reviewer: 22 David A. Baran Print Name Review Notes: 23 Independent review~

(For External Analyses Only)

External Approver: 24 Larry P. Lawrence Exelon Reviewer: 25 "~:;

p.

r t !1.!!..

AArif Name 0 L

!(,

~

t:f!1 !I ett

/,. // ,/

Independent 3t<1 Party R?J! Reqd) j Yes 0 Exelon Approver: 27

~k.. fteg/tvh~

Print Name

CC-AA*103-1003 Revision 13 CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 2 of 35 ATTACHMENT 2 Owner's Acceptance Review Checklist for External Design Analyses Design Analysis No.: _P_M_-1_2_0_9_ _ _ _ _ _ _ _ __ Rev:O Contract#: -=S-=1=13::;.,;0=3~------- Release#: .....

39.....9.___ _ _ _ __

No Question Instructions and Guidance Yes I No IN/A 1 Do assumptions have All Assumptions should be stated In clear terms with enough sufficient documented justffication to confirm that the assumption is conservative.

rationale?

For example, 1) the exact value of a particular parameter may not be known or that parameter may be known to vary over the range of conditions covered by the Calculation. It is appropriate to represent or bound the parameter with an assumed value. 2) The predicted performance of a specific piece of equipment in lieu of actual test data. It is appropriate to use the documented opinionfposition of a recognized expert on that equipment to represent predicted equipment performance.

Consideration should also be given as to any qualification testing that may be needed to validate the Assumptions. Ask yourself, would you provide more justification if you were performing this analysis? If yes, the rationale *is likely incom lete.

Are assumptions Ensure the documentation for source and rationale for the 0 2 compatible with the assumption supports the way the plant is currently or will be way the plant is operated post change and they are not in conflict with any operated and with the design parameters. If the Analysis purpose is to establish a licensing basis? new licensing basis, this question can be answered yes, if the assum tion su orts that new basis.

3 Do all unverified If*there are unverified assumptions without a tracking assumptions have a mechanism Indicated, then create the tracking item either tracking and closure through an ATI or a work order attached to the implementing mechanism in place? WO. Due.dates for these actions need to support verification prior to the analysis becoming operational or the resultant 1ant chan e bein o authorized.

4 Do the design inputs The origin of the input, or the source should be identified and have sufficient be readily retrievable within Exelon's documentation system.

rationale?.... If not, then the source should be attached to the analysis. Ask yourself, would you provide more justification if you were performing this analysis? If yes, the rationale is likely incom lete.

5 Are design inputs The expectation is that an Exelon Engineer should be able to V 0 correct and reasonable clearly understand which input parameters are critical to the with critical parameters outcome of the analysis. That is, what is the impact 6f a identified, if

change irt the parameter to the results otthe analysis? If the a ro riate? im act is lar e then that arameter is critical.

6 Are design inputs Ensure the documentation for source and rationale for the comR~tible with the_ . inputs supports.the way the plant is cur~ently or will I:>~ .

'- way the plant is i * ! ' *. ** ~ operated *post:change and*they.are.not.in conflict with:any operated and with the design parameters.

licensin basis?

CC-AA-103-1003 Revision 13 CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 3 of 35 ATTACHMENT 2 Owner's Acceptance Review Checklist for External Design Analyses Design Analysis No.: ....P.....

M.....-..20....9..___ _ _ _ _ _ _ _ __ Rev:_o_ _

1...

No Question Instructions and Guidance 7 Are Engineering See Section 2.13 in CC-AA-309 for the attributes that are Judgments clearly sufficient to justify Engineering Judgment. Ask yourself, documented and would you provide more justification if you were performing

ustitied? this anal sis? If es the rationale is likel incom lete.

8 Are Engineering Ensure the justification for the engineering judgment D D Judgments compatible supports the way the plant is currently or will be operated with the way the plant is post change and is not in conflict with any design operated and with the parameters. If the Analysis purpose is to establish a new licensing basis? licensing basis, then this question can be answered yes, if the *ud ment su orts that new basis.

9 Do the results and Why was the analysis being performed? Does the stated D D conclusions satisfy the purpose match the expectation from Exelon on the proposed purpose and objective of application of the results? If yes, then the analysis meets the Desi n Anal sis? the needs of the *contract.

10 Are the results and Make sure that the results support the UFSAR defined conclusions compatible system design and operating conditions, or they support a with the way the plant is proposed change to those conditions. If the analysis operated and with the supports a change, are all of the other changing documents licensin basis? include.d on .the cover sheet as *im .acted documents?

11 Have any limitations on Does the analysis support a temporary condition or the use of the results procedure change? Make sure that any other documents been identified and needing to be updated are included and clearly delineated in transmitted to the the design analysis. Make sure that the cover sheet appropriate includes the other documents where the results of this or anizations? anal sis rovide the in ut.

12 Have margin impacts Make sure that the impacts to margin are clearly shown. D been identified and within the body of the analysis. If the analysis results in documented reduced margins ensure that this has been appropriately appropriately for any dispositioned in the EC being used to issue the analysis.

negative impacts (Reference ER-AA-2007?

13 Does the Design Are there sufficient documents included to support the D Analysis include the sources of input, and other reference material that is not applicable design basis readily retrievable in Exelon controlled Documents?

documentation?

14 Have all affected design Determine if sufficient searches have been performed to analyses been identify any related analyses that need to be revised along documented on the with the base-analysis. It may be necessary to perform . .*

Affected Documents List some basic searches to validate this.

(AOL) for the associated *.._.:-

Confi uration Chan e?.

15 Do the sources of inputs , Compare any referenced codes :and.standard!? to the current and analysis design basis and ensure that any differences are reconciled.

methodology used meet If the input sources or analysis methodology are based on committed technical and an out-of-date methodology or code, additional reconciliatlon regulatory may be required if the site has since committed to a more re uirements? recent code

CC*AA*103-1003 Revision 13 CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 4 of 35 ATTACHMENT 2 Owner's Acceptance Review Checklist for External Design Analyses Design Analysis No.: _P_M_-1_2_0_9_ _ _ _ _ _ _ _ __ Rev:O ---

No Question Instructions and Guidance Yes/No/ N/A 16 Have vendor supporting Based on the risk assessment performed during the pre-job _, u u technical documents brief for the analysis (per HU-M-1212), ensure that and references sufficient reviews of any supporting documents not provided (including GE DRFs) with the final analysis are performed.

been reviewed when necessarv?

17 Do operational limits Ensure the Tech Specs, Operating Procedures, etc. contain D D~

support assumptions operational limits that support the analysis assumptions and and inputs? inputs.

List the critical characteristics of the product1 and validate those critical characteristics.

18.

SEE BELOW Create an SFMS entry as required by CC-AA-4008. SFMS Number: --=5 . . . .9. .*.__9_0__,91"------

CRITICAL CHARACTERISTICS There are no acceptance criteria for this uncertainty. It is simply stated for use in preparation of the Cameron calculation.

The calculation determines the uncertainty in feedwater mass flow rate as calculated in the Plant Process Computer (PPC) by applying feedwater flow nozzle flow coefficients and density correction based upon measured feedwater inlet temperature to measured the differential pressure of feedwater flow across the nozzle.

Critical inputs were validated by examination of References 4.9, 4.10.1, 4.10.2, 4.10.3 and 4.11 of this calculation.

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 5 of 35 CALCULA TJON TABLE OF CONTENTS CALCULATION NO. PM-1209 REV. NO. 0 PAGE N0.5 SECTION: PAGE NO.

Cover Sheet 1 Owners Acceptance Review Checklist 2 Table of Contents 5 1.0 PURPOSE 6 2.0 INPUTS 7 3.0 ASSUMPTIONS 9

4.0 REFERENCES

11 5.0 IDENTIFICATION OF COMPUTER PROGRAMS 13 6.0 METHOD OF ANALYSIS 14 7.0 NUMERIC ANALvsrs AND RESULTS 15

8.0 CONCLUSION

S 35 Attachments Pages A E-mail, K. Schoenknecht to K. Cutler, April 6, 2017 A1 of A3 B Select Tables and Figures from ANSl/ASME PTC 6Report1985 81of84 c Rosemount 1151 Product Data Sheet 00813-0100-4360 C1 of C28 D RTP Corp Analog to Digital Converter Card RTP 8436/2X 01of02 E E-mail, May 10, 2002, D. McCully of RTP Corporation to J. Regan of E1 of E1 Key TechnoloQies Inc.

F Letter, T. Layer of Rosemount to E. Kaczmarski, June 24 1991, F1 of F2 Pressure Transmitter Performance Soecifications

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 6 of 35 1.0 PURPOSE The purpose of this calculation is to determine the feedwater'mass flow uncertainty in the plant process computer (PPC) as measured by a single feedwater flow nozzle differential pressure instrumentation loop, for the case in which this instrument loop has not been calibrated by the LEFM. The feedwater mass flow uncertainty is developed for the proposed MUR normal steady state operating conditions of temperature, pressure and flow.

The feedwater mass flow measurement is calculated within the PPC by applying flow coefficients and a density correction to the measured differential pressure of feedwater flow across the nozzle. The density correction is based on the measured feedwater inlet temperature.

The instrument loop uncertainties determined within this calculation are applicable to the following components:

Feedwater differential pressure:

Unit 2: FE-2-06-011A, FE-2-06-0118 1 FE-2-06-011 C FT-2-06-050A, FT..2-06-0508, FT-2-06-050C Unit3: FE-3-06-011A, FE-3-06-011 B, FE-3-06-011C FT-3-06-050A, FT-3-06-0508, FT-3-06-050C Feedwater temperature:

Unit 2: TE-2144A, TE-21448, TE-2144C, TE-21440, TE..2144E, TE-2144F TT-2144A, TT-21448, TT-2144C, TI-21440, TT-2144E, TT-2144F Unit 3: TE-3144A, TE-31448, TE-3144C, TE-31440, TE-3144E, TE-3144F TT-3144A, TT-31448, TT-3144C, TT-31440, TT-3144E, TT-3144F The single nozzle mass flow uncertainty determined within this calculation is intended as an input to the overall thermal power uncertainty calculation performed by Cameron as part of the upgrade to measure feedwater flow with the Cameron Leading Edge Flow Meter (LEFM) Checkplus Ultrasonic Flow Measuring System, for use in the cases in which one or more feedwater lines are measured by the nozzle, and it has not been corrected to the LEFM.

There are no acceptance criteria for this uncertainty. It is simply stated for use in preparation of the Cameron calculation.

If future modifications replace components in any of the analyzed loops, the cal~ulated uncertainty results will remain bounding as long as the replacement components are at least as accurate as those analyzed herein. If the calibration equipment is replaced or calibration processes are modified in the future, the calculated uncertainties remain bounding as long as the calibration equipment is at least as accurate as what is analyzed herein, and the calibration process maintains the same or smaller as left tolerances.

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 7 of 35 2.0 INPUTS 2.1 The nominal values for operation of Peach Bottom Units 2 and 3 at maximum MUR rated power of 4016 MWt are provided by calculation EE-0029 (Reference 4.11 ). The following inputs are taken from this calculation for each unit:

2.1.1 Total Feedwater Flow: 16.4440 Mlbm/hr; nominal flow per loop 5.4813 Mlbm/hr 2.1.2 Feedwater Temperature: 383.4°F 2.1.3 Full calibrated span per loop: 8.0000 Mlbm/hr 2.1.4 Operating differential pressures (dP, or h) for nominal rated MUR temperature and flow:

Flow Element inwc FE-2-06-11A hr2A= 301.2 FE-2-06-11 B hr2B = 304.2 FE-2-06-11 C hr2C = 301.8 FE-3-06-11A hr3A = 301.2 FE-3-06-11 B hr3e = 302.4 FE-3-06-11 C hr3C = 302.4 Table 2.1.4 - MUR Nominal Rated Operating dP, hr 2.1.5 Operating differential pressures for full span flow, at 376.1°F:

Flow Element inwc FE-2-06-11A hs2A = 638.6 FE-2-06-11 8 hs2e = 645.0 FE-2-06-11 C hs2c = 639.9 FE-3-06-11A hS3A= 638.6 FE-3-06-11 B hs3B = 641.2 FE-3-06-11 C hsac = 641.2 Table 2.1.5 - Full Span Operating dP, hs 2.2 From References 4.9, 4.10 and 4.11, the 30 Monicore program in the PPC calculates feedwater mass flow based on the differential pressure points 8044, 8045, 8046, 8344, 8345 and 9346 as follows:

Unit2:

A Loop: 8018 = N8CFW001*8516

SQRT(B044) 8 Loop: 8019 = NSCFW002

5517

SQRT(8045)

C Loop: =

8020 NSCFW003

8518

SQRT(B046)

Unit3:

A Loop: 8318 = NSCFW301

8816

SQRT(B344)

B Loop: 8319 = N8CFW302

8817

SQRT(B345)

C Loop: 8320 = NSCFW303 * $818

SQRT(B346)

Flow correction constants 8516, 8517, 8518, 8815 1 8816 and 8817 are from Reference 4.11 (EE-0029 Rev. 5).

Unit 2 8516 = 10.27333 =

Unit 3 8816 10.25728

=

8517 10.34251 =

5817 10.37076 5518 = 10.23560 8818 = 10.21455 NSCFWXOX = FWC2*(1.0 + DT*(FWC4) + DT

FWCS))

(all six NSCFWOOX and N8CFW30X terms use the same equation)

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 8of35 Feedwater Coefficient (CFW):

DT(I) = TFW(I)- FWC(3,I)

CFW - Feedwater Coefficients used for temperature compensation:

CFW(I) = FWC(2, 1)*(1.0+DT(l}*(FWC(4, l)+DT(l)*FWC(5,I)))

Where: I identifies the Feedwater branch

=

FWC2 3.09400E-02 FWC3 = 3. 761 OOE+02

=

FWC4 -3.35720E-04

=

FWC5 -4.14750E-07 TFW is the average feedwater temperature in each of the 3 feedwater branches CA0(3)83, CA0(3)84, CA0(3)85: FDWTR VENTURI CORRECTION FACTOR, from 0.5 to 1.5. 8018 is multiplied by CA083 to correct the venturi flow to the LEFM. The result goes to WFWBX1 (typ).

This calculation determines the uncertainty of the feedwater flow in the case that the LEFM has not been used to correct the venturi, so within this calculation, the correction factor is set to 1 and is 1

not used.

2.3 From References 4.11 and 4.4.17 the feedwater operating pressure is 1100 psig.

2.4 Per Reference 4.17 (included as Attachment F), all Rosemount specifications written as +/- implies random uncertainty, and the performance specifications of Rosemount Model 1151 transmitters are stated as 3cr values (3 standard deviations), with the exception of stability (drift) which is a 2a value 2.5 References 4.4.6 through 4.4.16 show the installation of the feedwater flow nozzles. The first upstream obstruction in each case is a 90° bend, with the exception of FE-3-06-011 B, which has a combination of a 45° bend with a 90° bend in a different plane. The first downstream obstruction is a tee in each case.

Nozzle Upstream Distance Downstream Distance (inches) (Inches)

FE-2-06-011A 90° bend 268.75 Tee 85.5 FE-2-06-011 B 90° bend 310.7 Tee 85.5 FE-2-06-011 C 90° bend 268.75 Tee 85.5 + 3 diam FE-3-06-011A 90° bend 268.75 Tee 85.5 FE-3-06-011 B 45° bend with 90° bend in 186.75 Tee 85.5 different plane FE-3-06~011 C 90° bend 310.7 Tee 85.5 + 3 diam Table 2.5 - Feedwater Line Obstructions

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 9of35 3.0 ASSUMPTIONS 3.1 For calculation of the loop uncertainties, if the confidence level of a published uncertainty is not stated, the information shall be assumed to be 2o (Reference 4.1 ).

3.2 For calculation of the loop uncertainties, the insulation resistance error is considered negligible because operation of the instrumentation in an abnormal or harsh environment is not considered by this calculation.

3.3 It is expected that regulated instrument power supplies are designed to function within supply voltage limits. Therefore, the power supply error is considered negJigible with respect to other error terms.

3.4 For calculation of the loop uncertainties, if temperature, humidity and pressure errors are not stated by the manufacturer an evaluation is made to ensure that the instrument environmental conditions are bounded by the manufacturer's specified operational limits. If the environmental conditions are bounded, these error effects are considered to be included in the manufacturer's reference accuracy.

3.5 All instruments are located in mild or very low dose environments. For the calculation of the instrument loop uncertainties, radiation induced errors associated with the normal environments have been incorporated only when provided by the manufacturer, and only if the manufacturer's specified effect is based on a dose of at the least the same order of magnitude as the 60 year TIO for that location. Otherwise, these errors are considered to be small enough to be adjusted out each time the instrument is re-calibrated, and so are considered to be included within the instrument drift related errors. Radiation induced errors associated with the normal environment are considered to be negligible if the 60 year TIO for that location is at least an order of magnitude less than the level specified for the manufacturer's radiation effect.

3.6 For the calculation of the instrument loop uncertainties, seismic effects are not applicable, because the core thermal po~er uncertainty calculation pertains only to normal full power operation and does not include abnormal operating conditions. Any seismic effects are considered negligible or capable of being calibrated out.

3.7 For the calculation of the instrument loop uncertainties, per the methodology in CC-MA-103-2001 (Reference. 4.1), if there is no drift stated by the manufacturer, the drift may be taken as equal to the required accuracy value. In the case of the RTP computer input and output cards analyzed within this calculation, it is further assumed that the drift value is equal to the vendor accuracy of the card.

3.8 For the calculation of the instrument loop uncertainties, per the methodology in CC-MA-103-2001 (Reference. 4.1 ), the required accuracy is taken as the larger of either the vendor accuracy or the calibration setting tolerance.

3. 9 As stated in Foreword to ANSl/ASME PTC 6 Report*1985 (included in Reference 4.12}, the possible errors associated with steam turbine testing are expressed as uncertainty intervals which, when incorporated into this model, will yield an overall uncertainty for the test result which provides 95% coverage of the true value. Therefore, it is assumed that the overall uncertainty of the flow section represents a 2a value.

3.10 As stated in Note 1 of ANSl/ASME PTC 6 Report - 1985 (Reference 4.12), the overall uncertainty value of the flow element is acceptable for flow elements in service for less than six months.

Further, Section 4.17 of this report states that the base uncertainty for flow elements in service for more than six months is likely to change much less with time than indicated for the initial six months. It is therefore assumed that any additional error due to damage or deposits on the flow element will have a negligible impact on the overall loop uncertainty. Since the flow element has been in service greater than six months, for conservatism, the largest Group 1 base uncertainty from Table 4.10 from Reference 4.12 (included in Attachment B) will be used to evaluate the overall flow element errors. As documented in EE-0029 (Reference 4.11 ), tracer testing was used in 1992

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 10 of 35 to calibrate the Unit 2 feedwater flow measurement, and ultrasonic testing was used in 1999 to calibrate the Unit 3 feedwater flow measurement. Under normal operating conditions, the LEFM is used to adjust the feedwater flow measured by the nozzles, this calibrating the nozzle measurement to the LEFM measurement, thus these flow elements may be considered to have been calibrated. Based on this, the largest Group 1 (calibrated) base uncertainty from Table 4.10 from Reference 4.12 is conservatively used to evaluate the flow element error.

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 11of35

4.0 REFERENCES

4.1 CC-MA-103-2001, Revision 2, Setpoint Methodology for Peach Bottom Atomic Power Station and Limerick Generating Station 4.2 NEDC-31336P-A, September 1996, "General Electric Company Instrument Setpoint Methodology (Proprietary)"

4.3 llSCP Data Sheets for:

FT-2-06-050A, FT-2-06-0508, FT-2-06-050C FT-3-06~050A, FT-3-06-0508, FT-3~06-050C TE-2144A, TE-21448, TE-2144C, TE-21440, TE-2144E, TE-2144F TE-3144A, TE-31448, TE-3144C, TE-31440, TE-3144E TE-3144F 1

TT-2144A, TT-21448, TT-2144C, TT-21440, TT-2144E, TT-2144F TT-3144A, TT-31448, TT-3144C, TI-3144D, TT-3144E, TT-3144F 4.4 Peach Bottom Station drawings:

4.4.1. E-1021 Sh. 0001, Revision 29 1 Cable Spreading and Computer Room Arrangement 4.4.2 M-1-S-25 Sh. 8, Revision 59, Electrical Schematic Diagram Feedwater Control System 4.4.3 M-1-S-25 Sh. 18, Revision 59, Electrical Schematic Diagram Feedwater Control System 4.4.4 E-269 Sh. OOA37, Revision 1, Electrical Schematic and Connection Diagram Computer -

Analog Points 4.4.5 E-269 Sh. OOA18, Revision 24, Electrical Schematic and Connection Diagram Computer -

Analog Points 4.4.6 M-180, Revision 11, Piping and Mechanical Feedwater Piping System and Supports - Plan 4.4.7 M-181, Revision 4, Piping and Mechanical Feedwater Piping System and Supports Unit No.

2 4.4.9 M-194, Revision 10, Piping and Mechanical Feedwater Piping System and Supports 4.4.1 O M-195, Revision 2, Piping and Mechanical Feedwater Piping System and Supports Unit No.

3 4.4.11 JS0-2-6-18, Revision 9, Piping Isometric RefDwg M-180, M-181, HIS0-601, M-1817 Bill of Material 4.4.12 JS0-2-6-19t Revision 5, Piping Isometric Ref Dwg M-180, M-181, HIS0-601, Bill of Material M-31 4.4.13 IS0-3-6-2, Revision 8, Piping Isometric Ref Dwg M-194, HIS0-651 4.4.14 IS0-3-6-4, Revision 8, Piping Isometric Ref Dwg M-194 1 HIS0-651 4.4.15180-3-6-5,* Revision 7, Piping Isometric Ref Dwg M-194, HIS0-651 4.4.16 IS0-3-6-6, Revision 6, Piping Isometric Ref Dwg M-194, HIS0-651 4.4.17 M-1-MM-1 Sh. 1, Revision 3, Outline, Dimensional Data Type TS Flow Nozzles Demineralized Water 4.4.18 A-12, Revision 35, Architectural Floor Plan 135FT-OOIN Floor Plan 116 4.4.19 M-577, Revision 12, Instrument Location Turbine Building Unit No 2 Plan at El 135FT-OOIN (Conv to History Cat F) 4.5 Peach Bottom Station Surveillance Instructions:

4.5.1 Sl2F-6-50-ACC2, Revision 5, Calibration Check of Reactor Feedwater Flow Transmitters FT 2-6-50A, Band C

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 12 of 35 4.5.2 Sl3F-6-50-ACC2, Revision 6, Calibration Check of Reactor Feedwater Flow Transmitters FT 3-6-50A, B and C 4.5.3 Sl2T-6-2144-AFC2 1 Revision 9, Calibration Check of Feedwater Inlet Temperature Instruments TE 2144A, B, C, D, E and F and TT 2-6-2144A, B, C, D, E and F 4.5.4 Sl3T-6-3144-AFC2, Revision 10, Calibration Check of Feedwater Inlet Temperature Instruments TE 3144A, B, C, D, E and F and TT 3-6-3144A, B, C, D, E and F 4.6 PassPort data (viewed 04-13-2017) for:

FE-2-06-011 A, FE-2-06-0118 1 FE-2-06-011 C FE-3-06-011A, FE-3-06-0118 1 FE-3-06-011C FT-2-06-0SOA, FT..2-06-0508, FT-2-06-050C FT-3-06-050A, FT-3-06-0508, FT-3-06-050C TE-2144A, TE..21448, TE-2144C, TE-21440, TE-2144E, TE-2144F TE-3144A, TE..31448, TE-3144C, TE-31440, TE-3144E, TE-3144F TT-2144A, TI-21448, TT-2144C, TT-2144D, TT-2144E, TT-2144F TT-3144A, TT-31446, TT-3144C, TT-3144D, TT-3144E, TT-3144F 4.7 NE-00164, Revision 6, Specification for Environmental Service Conditions Peach Bottom Atomic Power Stations Units 2 & 3 4.8 R-369-VC-26, Revision 1, Models 3144 and 3244MV Smart Temperature Transmitters (Rosemount 0809-0100-4724 Rev. CA) 4.9 E-mail, K. Schoenknecht to K. Cutler, April 6, 2017 (included as Attachment A) 4.10 Peach Bottom Vendor Prints:

4.10.1 S-102-VC-25, Revision 2, Requirements Specification for the PMS 3D Monicore Interface 4.10.2 S-102-VC-31, Revision 4, PMS 30 Monicore Interface Software Design Description 4.10.3 S-102-VC~40, Revision 0, Requirement Spec for Peach Bottom LESM CheckPlus PMS Interface 4.10.4 S-102-VC-41, Revision 1, LESM PMS Interface Detail design Document 4.11 EE-0029, Revision 5, Determine Proper Calibration of F/W Flow Transmitters FT-2(3)-6-0SOA(B)(C) 4.12 ANSl/ASME PTC 6 Report 1985, Guidance for Evaluation of Measurement Uncertainty in Performance Tests of Steam Turbines (Select pages included in Attachment B) 4.13 Product Data Sheet 00813-0100-4360 Revision JB, March 2010, Rosemount 1151 Pressure Transmitter (included as Attachment C) 4.14 RTP Corporation Product Specification Sheet, Analog to Digital Converter Card Model RTP 8436/2X Series, December 2001 (included as Attachment D) 4.15 Peach Bottom Updated Final Safety Analysis (UFSAR) Revision 26 1 April 2017, Section 10.15.3.4, Miscellaneous Rooms and Buildings 4.16 Email dated May 10, 2002 from Dave McCully of RTP Corporation to J. Regan of Key Technologies Inc. providing specifications for RTP Bridge Card and AID Conversion (included as Attachment E) 4.17 Rosemount Letter, June 24, 1991, T. Layer to E. Kaczmarski, Pressure Transmitter Performance Specifications (Attachment F)

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 13 of 35 5.0 IDENTIFICATION OF COMPUTER PROGRAMS Microsoft Excel 2013 was used on a Microsoft Windows 7 operating system as a desktop productivity tool to perform numerical calculations in the preparation of this calculation. Microsoft Excel is exempt from the DTSQA requirements of IT-AA-101. All computations are shown in the calculation and are not dependent on the software.

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 14 of 35 6.0 METHOD OF ANALYSIS 6.1 The methodology used to calculate the loop uncertainties is based on CC-MA-103-2001 "Setpoint Methodology for Peach Bottom Atomic Power Station and Limerick Generating Station" (Reference 4.1 ), which is based on GE Setpoint Methodology (Reference 4.2). ln accordance with this methodology, independent error terms are combined via square root sum of the squares (SRSS) and taken to a 2a confidence level. Dependent errors are combined according to their dependency relationships and biases are algebraically summed. In accordance with this methodology, if no vendor drift is stated, then a drift value equal to the required accuracy may be used. For computer cards, per Assumption 3.7, the drift value is taken as the vendor accuracy term.

6.2 For calculation of the loop uncertainties, if the confidence level of a published uncertainty cannot be ascertained, the information shall be assumed to be 2a (Assumption 3.1, Reference 4.1 ).

6.3 Instrument calibration setting tolerance represents 100% of the population, and so is applied as a 3a error.

6.4 For calculation of the loop uncertainties, temperature, humidity and pressure errors, when available from the manufacturer, are evaluated with respect to the environmenta1 service conditions in specification NE-00164 (Reference 4.7). If not provided, an evaluation is made to ensure that the environmental conditions are bounded by the manufacturer's specified operational limits. If the environmental conditions are bounded, these error effects are considered to be included in the manufacturer's reference accuracy. (Assumption 3.4).

6.5 ASME PTC-6 (Reference 4.12) is used to determine the error in the flow nozzles. PTC-6 is used because it provides a very conservative means to quantify the flow nozzle uncertainties, and it takes into account the upstream and downstream flow disturbances due to piping configurations.

6.6 Development of U~certainty Equations

.For a function Y of multiple variables (x1), such as:

Y = f(x1, X2, Xa, ..* , Xn) Equation 6.6*1 The change in Y due to changes in the Xn variables is:

Equation 6.6*2 (c3Y) (oY) (oY) dY = -- ax1 dx1 + - - dx 2 + ... + -

OXz OXn dxn If the variables are independent of each other, and their uncertainties are independent of each other, then the uncertainty (Uv) in Y resulting from the combination of the independent uncertainties in the independent Xn variables is calculated as the square root of the sum of the squares:

Equation 6.6*3 BY z oY 2 ay 211/2 Uy = [ (-

ox1

ax1) +. (OXz -

CTXz) + *** + (OXn

-

O'Xn)

For dependent variables Xn, or dependent uncertainties, the uncertainty is a sum:

Equation 6.6-4 Feedwater differential pressure and temperature are measured via independent instruments. There are no dependent uncertainties between the separate instrument loops, so all input variables and their uncertainties are modeled as independent.

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 15 of 35 7.0 NUMERIC ANALYSIS AND RESULTS This section determines the uncertainties of the instrument loops that measure feedwater flow differential pressure and feedwater temperature, and the uncertainty of the mass feedwater flow as calculated in 30 Monicore.

7.1 Feedwater Nozzle Uncertainty Per methodology Section 6.5, this section determines a bounding uncertainty for the feedwater flow nozzles, based on PTC-6 (Reference 4.12 1 applicable Tables and Figures are included in Attachment 8) 1 for the case in which the flow nozzle has not been calibrated to the LEFM. Per References 4.4.6 through 4.4. 17, the feedwater flow nozzles do not have upstream flow straighteners, therefore the overall flow nozzle uncertainty (U) determined based on the combination of the following terms:

U= +juj+ufNs+ UJ+ UAsL Equation 7.1-1 Ue :; base uncertainty of the nozzle, from Table 4.10 of Reference 4.12 ULNS =minimum upstream straight run uncertainty, from Table 4.11 and Figure 4.5 of Reference 4.12 U13 = beta ratio effect, from Figure 4.6 of Reference 4.12 UosL = minimum downstream straight run uncertainty from Figure 4.9 of Reference 4.12 First the nearest upstream and downstream bends are determined based on review of the applicable isometric drawings. Then the values from the applicable PTC-6 tables and figures are used to determine the applicable individual uncertainties. Lastly, these uncertainties are combined via SRSS as shown in Equation 7.1-1 above.

Upstream and Downstream Bends:

From Input 2.5, this is a list of the first upstream and downstream obstruction for each feedwater nozzle.

The distance in inches is divided by the 15.688 inch pipe diameter (Reference 4.11) to get the number of diameters.

Nozzle Upstream Distance No. of Downstream Distance No. of (inches) Diameters (inches) Diameters FE-2-06-011A 90° bend 268.75 17.1 Tee 85.5 5.4 FE-2-06-0118 90° bend 310.7 19.8 Tee 85.5 5.4 FE-2-06-011C 90° bend 268.75 17.1 Tee 85.5 + 3 diam 8.5 FE-3-06-011A 90° bend 268.75 17.1 Tee 85.5 5.4 FE-3-06-0118 45° bend with 90° 186.75 18.3 Tee 85.5 5.4 bend in different plane FE-3-06-011 C 90° bend 310.7 19.8 Tee 85.5 + 3 diam 5.4 Table 2.5 - Feedwater Line Obstructions Reference 4.12 classifies the error terms calculated here as random errors. Per Assumption 3.9 the flow element error is taken as a 20' confidence level Base Uncertainty (Ual Per Assumption 3.10, the largest Group 1 base uncertainty from Table 4.10 of Reference 4.12 is conservatively used for both units, for a calibrated flow nozzle. Thus Us = 2.5%.

Minimum Upstream Straight Run Uncertainty (ULNsl For Unit 2, the most restrictive upstream case is a straight run of 17.1 diameters from a 90° bend.

Interpolating the values in Column 1 of Table 4.11 of Reference 4.12 for a beta ratio of 0.6597, the 1

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 16 of 35 denominator for the upstream length ratio is 12 diameters. The upstream length ratio is then: straight length ratio= 17.1 diameters/12 diameters= 1.43. The minimum straight run uncertainty (ULNs) is taken from Figure 4.5 of Reference 6 and is approximately 1.5% of flow.

For Unit 3, the most restrictive case is a combination of 45° and 90° bends in different planes, 18.3 diameters upstream. Interpolating the values in Column 2 of Table 4.11 of Reference 4.12, for a beta ratio of 0.6597 the denominator for the upstream length ratio is 17 diameters. The upstream length ratio is then:

1 straight length ratio= 18.3 diameters/17diameters=1.08. The minimum straight run uncertainty (ULNs) is taken from Figure 4.5 of Reference 4.12 and is approximately 1.90% of flow.

Beta Ratio Uncertainty (Uq)

From above, [3 = 0.6597. From Figure 4.6 of Reference 4.12, the beta ratio effect Up for a calibrated flow element is 0.33% of flow.

Minimum Downstream Straight Run Uncertainty CUosL)

For both units, the most limiting downstream straight run is tee 5.45 diameters downstream of the nozzle.

From Table 4.11 of Reference 4.12, the denominator for the minimum downstream length ratio from Column 7 is 4 diameters. The downstream length ratio is 5.45 diameters/4 diameters = 1.36. The minimum straight run uncertainty (UosL) is taken from Figure 4.9 of Reference 4.12 and is approximately 0.35% of flow.

The overall flow element measurement uncertainty is determined below, utilizing Equation 7.1-1. Per Assumption 3.9, this error is taken as a random 2o term.

Unit2 UFEZ = +~Uj + utNs2 + uff + UJs, LIFE2 = +/- [(2.5%) 2 + (1.5%) 2 + (0.33%) 2 + (0.35%)2] 0*5 UFe2 = +/- 2.95 % of flow [2o}

Unit3 j UF63 = + Uj + U°fN~ + Uff + UJ5 ,

UFE3 = +/- ((2.5%)2 + {1.9%) 2 + (0.33%) 2 + (0.35%)2]0*5 UFe3 =+/- 3.18 % of flow [2o]

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 17 of 35 7.2 Feedwater Flow Differential Pressure Measurement Loop Uncertainty Loop configuration The analyzed feedwater flow loop consists of the following: flow element, differential pressure transmitter, and PPC analog input (Al) card with a precision resistor across the input. The loop configuration is shown below (Input 2.1, Refs. 4.3, 4.4.2, 4.4.3, 4.5.1, 4.5.2):

MODULE3 MODULE 1 MODULE 2 30.4-*152 PPCAI 0-8.-000 . FE-2(3)*06-011A * - - -

FT-2(3)-06-050A Point range mV 8044 (8344)

Mlbm/hr FE-2(3)-06-011 B ., FT-2(3)-06-0508 0-hslnwc 0-hs 8045 (8345)

FE-2(3)-06-011 C lnwc dP FT-2(3)-06-050 u + - - - - c J - - - - + u 8046 (8346) 7.60.+/-0.1%

Gain k1 = Galnk2=

(16 mA) I (hs lnwc) + 4 mA {hs lnwc) I (121.6 mV)

Module 1 The flow element develops a differential pressure output based on the square of the flow input. For any flow FN = k(hN} 112, for MUR rated flow Fr= k(hr) 112 and for full span flow Fs = k(hs) 112 ,

solving each of these for constant k: k =FN/(hN) 112 =Fs/(hs) 112 =Frl(hr}112 or hN = hr* FN2 I Fr2 Equation 7.2-1a or hs =hr* Fs2 I Fr2 Equation 7.2-1 b This relationship is used to determine h at the points of interest.

Module 2 The transmitter output is linear with respect to the input. thus for any input X (in inwc), the transmitter output T (in mA) is defined as:

Equation 7.2-2 (16 mA) .

T = (h .

5lllWC

)

X mwc + 4 mA For any error ox (in inwc) taken through the transmitter to find error in OT (in mA):

Equation 7.2*3 (16 mA)

G =er*---

T x (hs inwc)

Across Resistor The mV output across the resistor for any mA input is: Equation 7 .2-4 (121.6 mV)

T= (l 6 mA) * (X - 4)mA + 30.4 mV Module 3 For the differential pressure computer points, the output is linear with respect to the input:

Equation 7.2-5 (hs inwc)

T = (lZl. 6 mV) * (x - 30.4) mV For any error ox (in mV) taken through the point to find error in O'T (in inwc):

Equation 7.2-6 (h5 inwc) crT = crx * (121.6 mV)

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 18 of 35 The analyzed loop components (and their applicable data) are as follows:

Module 1- Flow Element FE 2(3)-06-011A, B, C Make/Model Nozzle/GE Permutit 556-26400 (Reference 4.4.17)

Performance Specifications: {Input 2.1 unless noted otherwise) 1 Maximum flow 8.0000 Mlbm/hr Nominal flow at rated power: 5.4813 Mlbm/hr Differential .pressure hr at nominal flow for MUR operating conditions, Table 2.1.4 from Input 2.1.4:

Flow Element inwc FE-2-06-011A hr2A = 301.2 FE-2-06-0118 hr2B =: 304.2 FE-2-06-011 C hr2c = 301.8 FE-3-06-011A hr3A = 301.2 FE-3-06-011 B h13a = 302.4 FE-3-06-011 C hr3C = 302.4 Table 2.1.4 - MUR Nominal Rated Operating dP, hr Differential pressure hs at full span flow, Table 2.1.5 from Input 2.1.5:

From Input 2.1.5 Flow Element FE-2-06-011A hs2A = 638.6 FE-2-06-0118 hs2s = 645.0 FE-2-06-011 C hs2c = 639.9 FE-3-06-011 A hs3A = 638.6 FE-3-06-011 B hs3B = 641.2 F.E-3-06-011 C hs3C = 641.2 Table 2.1.5- Full Span Operating dP, hs Accuracy Unit 2: +/- 2.95% of flow; Unit 3: +/- 3.18% of flow (Section 7.1)

Module 2 - Flow Transmitter FT 2(3)*06*050A, B, C Make/Model Rosemount Model 1151 DP5E22B2 {Reference 4.3)

Performance Specifications: (Reference 4.13, Input 2.4)

Operating Span hs {inwc) in table above Upper Range Limit (URL) 750 inwc Accuracy +/- 0.2% of calibrated span [3a]; includes combined effects of linearity, hysteresis and repeatability Drift (Stability) +/- 0.2% of URL for 6 months [2a] (range 5 code E) 1 Temperature Effect +/- (0.5% URL+ 0.18% cal span) per ambient temperature change of 100°F (55.6 °C) (30]

Static Pressure Zero Effect +/- 0.25% of URL for 2000 psi, correctable by re-zeroing at line pressure Static Pressure Span Effect Correctable to +/- 0.25% of URL for 1000 psi.

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 19 of 35 Note that although the static pressure zero and span effects are caused by a common static pressure condition, they are stated as two separate error effects by Rosemount and are treated as random independent errors per Attachment F and Input 2.4.

No radiation effect stated by manufacturer No seismic effect stated by manufacturer Operating Limits Temperature - 40°F to 200°F Humidity o- too % relative humidity Calibration Information (Input 2.1, Reference 4.3, 4.5.1, 4.5.2)

Operating Static Pressure 1100 psig (per Input 2.3)

Operating Span O- hs inwc Corresponding Process Range O- 8. 000 Mlbm/hr Required Accuracy +/- 0.5%, or +/- 0.08 mA, or +/- 0.02 Vdc Operating Output Span: 4-20mA Calibration As-Left Tolerance +/- 0.08 mA (0.5%), or+/- 0.02 Vdc Location lnfonnation (Reference 4.7, unless noted otherwise)

Location (Ref. 4.3 & 4.6) Unit 2: TB2, Rack 20C167, EL. 135', Corridor 219 (Ref. 4.4.18. 4.4.19)

Unit 3: T83, Rack 30C167, EL. 135', Corridor 264 (Ref. 4.4.18. 4.4.19)

Normal Temperature 65 °F (min.)/ 102.5 °F (max) / 85°F (normal)

Normal Pressure -0.25 inwc Normal Humidity 10 to 90% RH Radiation 6.43 E4 Rads (60 year TIO)

The temperature and humidity limits for this location are bounded by the manufacturer's specified operating limits so per Assumption 3.4 any temperature induced effects are included in the manufacturer's specified temperature effects and any humidity induced effect is considered to be included in the manufacturer's specified accuracy.

n A 7 .6 +/- 0.1 % tolerance resistor is used to convert the transmitter 4-20 mA output to a 30.4 .. 152.0 mV input to the PPC input card.

Module 3-lnput Card for PPC Point 8044, 8045, 8046 (8344, 8345, 8346), also called A1713, A1714,A1715(A2713,A2714,A2715)

Make/Model RTP 7436 Analog Input Card Performance S pacifications Card full scale voltage 160 mV (Ref. 4.16)

Input Signal Range 30.4 - 152 mV (4 .. 20 mA across a 7.6 n resistor) (Refs. 4.4.4 and 4.4.5)

Accuracy (12 bit) +/- 0.025% of full scale (Ref. 4.14)

Temperature Effect 50 ppm per °C =0.005%1°C (Ref. 4.14)

Drift Not stated Operating temperature range O - 55°C (32 -131 °F)

Operating humidity range 20% to 80% RH, non-condensing

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 20 of 35 dP Point Display 0 - hs inwc, read to 000.0 places Location Information (Ref. 4. 7, .unless noted otherwise)

Location (Ref. 4.3) Unit 2: Analog Input Cabinet, Room 301 Unit 3: Analog Input Cabinet, Room 301 Normal Temperature 65 °F (min.)/ 72 °F (max)

Normal Pressure 14.7 psia Radiation mild environment These temperature limits are bounded by the manufacturer's specified operating limits so per Assumption 3.4 any temperature induced effects are considered to be included in the manufacturer's specified temperature effects. The humidity limits of the Computer Room 301 are not stated in Reference 4.7, however, per Reference 4. 15 the computer room HVAC controls maintain a constant temperature and humidity. These cards have functioned successfully in these locations for many years. Thus per Assumption 3.4 any potential humidity induced error effects are considered to be included in the manufacturer's specified accuracy.

Calibration Information (Refs. 4.3, 4.5.1, 4.5.2)

The flow loop is calibrated by using a pressure source to simulate pressure input to the transmitter (measured by a pressure gauge of at least 2.5 inwc accuracy), and then reading the voltage to a tolerance of +/- 0.04 V (by a voltmeter of at least +/-0.02 V accuracy) across a 0.1 % tolerance 250 ohm resistor at the input to the feedwater control system, and reading the differential pressure computer point values to a tolerance of+/- 4.9 inwc.

Thus the calibration error is based on the +/- 2.5 inwc accuracy of the gauge used to read the input pressure, and the reading error of the computer point display. The reading error is the least significant digit of the display, which is +/- 0.1 inwc. The maximum surveillance interval is taken as 30 months, based on 24 months including a 25% late factor.

The +/- 4.9 inwc loop output tolerance is applied in place of the combined vendor accuracies of the transmitter and the PPC point analog to digital input card, since it is much larger than their combined vendor accuracies (Assumption 3.8).

Determination of Largest Eull Span Operating hs for use in Error Determinations and Units Conversions:

The determination or flow error terms, and their conversion between different units requires the use of a differential pressure value. It is most conservative to use a bounding value to encompass all possible values. The full span flow differential pressure values (hs) from Input Table 2.1.5, taken from Reference 4.11, are based on a slightly different temperature than is present for MUR operating conditions. Thus the values from Table 2.1.5 are compared to the values resulting from the application of Equation 7.2-1.b to find the largest hs, which will conservatively be used to find bounding values.

From above, hs =hr* f s 2 I Fr2 Equation 7.2*1 b Applying Equation 7.2-1b to hr2A = 301.2 inwc (Input 2.1.4), where Fs = 8.000 Mlbm/hr (Input 2.1.3) and Fr= 5.4813 Mlbm/hr (Input 2.1.1) hs2A =hr2A

Fs2 / Fr2A2 = (301.2 inwc)*(8.000 Mlbm/hr)2 / (5.4813 Mlbm/hr)2 hs2A = 641.6 inwc

CALCULATION NO. PM .. 1209 REVISION NO. 0 PAGE NO. 21 of 35 The following table applies Equation 7.2-1 b to all the hr values from Input Table 2.1.4:

Flow Element inwc inwc FE-2-06-011A hr2A = 301.2 hs2A = 641.6 FE-2-06-011 B h12e = 304.2 hs2a = 648.0 FE-2-06-011 C hr2C = 301.8 hs2c = 642.9 FE-3-06-011A hr3A = 301.2 hs3A = 641.6 FE-3-06-011 B hr3B = 302.4 hsae = 644.2 FE-3-06-011 C hr3c = 302.4 hS3C = 644.2 Table 7.2*1 - Full Span Operating hs per Eq. 7.2*1b The following table compares the hs values from Table 2.1.5 to the hs values from Table 7.2-1. The largest and smallest value for each unit is shown in bold.

From Input 2.1.5 Using Equation 7.2-1b Flow Element inwc inwc FE-2-06-011A hs2A = 638.6 hs2A = 641.6 FE-2-06-0118 hs2e = 645.0 hs2e = 648.0 FE-2-06-011 C hs2c = 639.9 hs2c = 642.9 FE-3-06-011 A hS3A = 638.6 hsaA = 641.6 FE-3-06-011 B hs3B = 641.2 hsae = 644.2 FE-3-06-011C hsac = 641.2 hsac = 644.2 Table 7 ..2-2 -Full Span Operating hs Comparison The largest and smallest values for each unit will be applied in the error determinations and unit conversions in order to produce the most conservative results (larger error).

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 22 of 35 Feedwater Flow Differential Pressure Loop Note: All error values are +/-

Module 1: FEM2(3)-06-011A B C1 1 Module 2: FT-2(3)-06-050A,B,C Module 3: PPC Point 8044, 8045, 8046 (8344, 8345, 8346), also called A1713, A1714, A1715 (A2713, A2714, A2715)

U2 Value U3Value Units MUR Total Nominal Flow FNT= {total, 3 loops) (lnout2.1.1) 16.4440 16.4440 Mlbm/hr

=

MUR Nominal *Rated Flow per loop FR = FNT/N, where N = 3 (number of loops) 5.4813 5.4813 Mlbm/hr

=

Full Span Flow per loco FS (Input 2.1.1) 8.0000 8.0000 Mlbm/hr hR = largest dP for rated MUR conditions= hr2B for U2; hr3B for U3 304.2 302.4 inwc

=

hRL = smallest (lowest) dP for rated MUR conditions hr2A for U2; hr3A for U3 301.2 301.2 inwc hSU = highest (upper) h at full span flow= hs2B for U2; hs3B for U3 (Table 7.2-2) 648.0 644.2 inwc hSL =lowest hat full span flow= hs2A for U2; hs3A for U3 (Table 7.2-2) 638.6 638.6 inwc Module 1: FE-2(3)-6-011A,B,C flow nozzle U2Value U3Value Units a UFE2 and UFE3 (Section 7.1) . 2.95 3.18 %

(Error conversions conservatively based on hR )

Flow and dP are found at UFE% above and below nominal rated flow FR:

Uooer nominal flow limit = FNU = (100 + UFE}%*FR 5.6430 5.6556 Mlbm/hr Lower nominal flow limit= FNL = (100 - UFE)%*FR 5.3196 5.3070 Mlbm/hr

=

hR =largest hat nominal rated flow= hr2B for Unit 2, hr3A for Unit 3 304.2 302.4 inwc

=

hat uooer nominal flow limit hNU hR * (FNU)A2 / (FR)"2 (per Eq. 7.2-1a) 322.41 321.94 inwc hat lower nominal flow limit hNL = hR * (FNL)A2 / (FR)"2 (per EQ. 7.2-1a) 286.52 283.47 inwc Uooer limit error= hNU - hR 18.2 19.5 inwc Lower limit error= hNL - hR *17.7 -18.9 lnwc Aoolv larQer of two in both directions:

Accuracy= A1 =PEA 18.2 19.5 inwc 2 PMA=O Determining maximum hNU and minimum hNL to bound all cases:

hNU max is as determined above 322.41 321.94 inwc hNL min is hR2A - PEA (hRL and PEA from above) 283.00 281.70 inwc

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 23of35 Module 2: FT-2(3)*06..Q50A,8,C (errors taken at hNU, hNL using hSU or hSL for max effect) U2Value U3 Value Units a Rosemount 1151DP5E2282 (Ref. 4.3)

Ooerating Static Pressure (Input 2.3) 1100 1100 psia Uooer Range Limit (URL) (Ref. 4.13) 750 750 inwc Output span: 4-20 mA, linear with dP 16 16 mA

mANU mA at hNU (hNU)*(16 mA)/(hSL inwc) + 4 mA (Per EQ. 7.2-2) 12.08 12.07 mA

=

mANL mA at hNL = (hNL)*(16 mA)/(hSL inwc} + 4 mA (Per Eq. 7.2-2) 11.09 11.06 mA

=

Vendor Accuracy= VA2' 0.2% of span = 0.25%* hSL inwc 1.6200 1.6105 inwc 3

=

Taken as a 2a value: VA2 VA2' *213 1.0800 1.0737 inwc 2 TE2' =Temp Effect= (0.5% URL + 0.18% span) /100°F taken from 65 - 102.5 3.0375 3.0197

°F as: (0.5%*(hSL inwc) + 0.18%(hSL inwc))*(102.5 - 65)/100 inwc 3 Taken as a 2a value: TE2 = TE2' *2/3 2.025 2.0131 inwc 2

=

SPE2Z Static pressure zero effect =(1100 psiQ)* 0.25% URU2000 Psig 1.0313 1.0313 inwc 3 SPE2S =Static Pressure span effect= (1100 psig) '* 0.25% URL/ 2000 psia 1.0313 1.0313 inwc 3

=

SPE21 SQRT(SPE2Z"2 + SPE2SA2) 1.4585 1.4585 inwc 3

=

Taken as a 2a value: SPE2 SPE2' *2/3 0.9723 0.9723 inwc 2

=

D2' 0.2% of URL for 6 months= 0.2%*(750 inwc) 3.3541 3.3541 inwc 2 Taken as a 2a value: D2 = D2' *2/3 2.2361 2.2361 inwc Radiation Effect - not applicable per Assumption 3.5 Seismic Effect - not applicable per Assumption 3.6 Module 3: PPC Point Al Card for 8044, 8045, 8046 (8344, 8345, 8346),

also called A1713, A1714, A1715 (A2713. A2714, A2715) U2Value U3Value Units a RTP 7436 Analoa Input Card Card full scale voltage 160 160 mV Max input Voltaae 152 152 mV Min input voltage 30.4 30.4 mV Voltaae span 121.6 121.6 mV

=

Vendor Accuracy= VA3' 0.025% full scale output= 0.025%*(160 mV) (Ref.

4.14) 0.4 0.4 mV 2 Convert to inwc per Eq. 7.2-6 as: VA3 = VA3'

hSU/(121.6 mV} 2.1316 2.1191 inwc 2 TE3' =Temp Effect= 50 ppm full output1°C, taken over 65 to 72°F as:

=

TE3 0.005%(160 mV)*(72-65)°F*(5°C/9°F) (Ref. 4.14) 0.0311 0.0311 mV 2 Convert to inwc per EQ. 7.2-6 as: TE3 = TE3'

hSU/(121.6 mV> 0.1657 0.1648 inwc 2

Drift 03 A3 (Assumption 3. 7) 2.1316 2.1191 inwc 2 Calibration setting tolerance= CST3' = 4.9 inwc 4.9 4.9 inwc 3 CST3 as 2a value: CST3 = CST3'*2/3 3.2667 3.2667 inwc 3 Accuracy= A23 = MAX(SQRT(VA2"2 + VA3"2),CST3) (Assumption 3.8) 3.2667 3.2667 inwc 2 Resistor Tolerance (taken at hNU and hSL for max effect))

=

Convert hNU to mA per Eq. 7.2-2: hNUmA (16 mA)/(hs inwc)*(hNU inwc) + 4 mA 12.0779 12.0661 mA

=

Convert hNUmA to mV per Eq. 7.2-4: hNUmV (121.6 mV)/(16 mA) *(hNUmA -

4)mA + 30.4 mV 122.19 122.10 mV Resistor tolerance= R1v= 0.1%*hNUmV 0.1222 0.1221 mV 2

=

Convert to inwc per Eq. 7.2-6 as: R1 R1v

hSL/{121.6 mV) 0.6511 0.6468 inwc 2

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 24 of 35 Differential Pressure Loop Calibration Error U2 Value U3Value Units a

=

Module 2 Input calibration error, based on accuracy of MTE = CLl2 2.5 inwc 2.5 2.5 inwc 2 Module 2 Cutout calibration error= CL02 = o (loop calibration)

Module 3 Input Calibration Error= CLl3 = O (loop calibration)

Module 3 Output Calibration Error, based on reading error of dP display = CL03

= 0.1 inwc 0.1 0.1 inwc 2

=

Module 2 Calibration Error = CC2 = SQRT(CLl2"'2 + CLQ21\2) CLl2 2.5 2.5 inwc 2

=

Module 3 Calibration Error= CC3 SQRT(CLl3"2 + CL03"'2) = CL03 0.1 0.1 inwc 2 Differential Pressure Loop Error Calculation U2Value U3 Value Units a Loop Accuracy:

=

LA SQRT(A 11\2 + VA2"'2 + TE2"2 + SPE2A2 + A3"'2 + TE3A2 + R11\2) 18.6389 19.9089 inwc 2

=

Loop Ori~ LO SQRT(D2A2 + 03"'2) 3.9587 3.9587 lnwc 2

=

Loop Calibration Error: LC SQRT(CC2"2 + CC3"2) 2.502 2.502 inwc 2 Loop error: al =SQRTCLA"2 + LCA2 + LD"2) 19.2182 20.4523 inwc 2

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 25 of 35 7.3 Feedwater Temperature Measurement Uncertainty Loop configuration The analyzed feedwater Reactor Feed Pump temperature loop consists of an RTD wired to a temperature transmitter that sends a signal to the PPC through an analog to digital (AID) converter. The loop configuration is shown below (Refs. 4.4.4, 4.4.5, 4.4.9, 4.16):

PPCAI TT-2(3)144A, D MOSS, M060 (M358, M360)

TT-2(3)1448, E 4-20mA M057, M059 (M357, M359)

TT-2(3)144C 1 F 8011, M019 (8311, M319)

MODULE 1 MODULE2 1200+/- 0.02% MODULE3 90-400 Of 90-400 °F The analyzed loop components (and their applicable data) are as follows:

Module 1 - Temperature Element Module 1: TE-2(3)144A, B, C, D, E, F Make/Model: Pyco 22-4079-4.1-12. 75, 100 0 platinum RTD (Reference 4.3)

Perform anee Specifications:

Required Accuracy +/- 0.25% of span (Reference 4.3)

Drift not specified Calibration Information (Reference 4.3, 4.5.3, 4.5.4)

Output Span: ohm output varies with element, but corresponds to 90 to 400 °F Corresponding Process Range 90 to 400 °F Location Information (Reference 4.7, unless noted otherwise)

Location (Ref. 4.3) Unit 2: T2-89, T2-91, T2-93, EL. 165', Area 07, RFP Room Unit 3: T3-90, T3-91, T3-93, EL. 165', Area 07, RFP Room Normal Temperature 65 °F (min.)/ 112.1 °F (max)/ 85°F (normal)

Normal Pressure -0.25 inwc Normal Humidity 10 to 90% RH Radia1ion 6.43 E4 Rads (60 year TID)

Module 2-Temperature Transmitter TT-2(3)144A, B, C, D, E, F Make/Model Rosemount 3144 (Ref. 4.3)

Performance Specifications (Ref. 4.8, unless noted otherwise)

Input Signal Range ohms matched to input element (112.586 to 177.628 ohms, typical)

Output Signal Range 4 - 20 mA Required Accuracy ~ 0.125%, or +/- 0.02 mA (Ref. 4.3)

Digital Accuracy +/- 0.18 °F D/A Accuracy +/- 0.02% of span Total vendor accuracy is sum of digital and D/A accuracies

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 26 of 35 Stability (Drift) +/-0.1 % of reading or 0.1°c, whichever is greater, for 24 months Power Supply Effect +/-0.005% of span per volt Decade box tolerance +/- 0. 082 ohms Gain Adjustment (covered by calibration tolerance)

Temperature Effect 0.0015 °C + 0.001 % of span per 28°C change in ambient Temperature Limits - 40 to 185 °F (ambient, operational)

Humidity Limits 0-100%RH Location Information (Reference 4.7, unless noted otherwise)

Location (Ref. 4.3) Unit 2: T2-82, EL. 150', Area 03, Comp. Room 301, Cabinet C431 Unit 3: EL. 150', Area 031 Comp. Room 301, Cabinet C430 Normal Temperature 65 °F (min.)/ 72 °F (max)

Normal Pressure 14.7 psia Radiation mild environment Module 3- Input Card for PPC Point M057, MOSS, M059, M060, 8011, M019 (M357, M358, M359, M360, 8311, M319)

Make/Model RTP Analog Input Card Performance Specifications Input Signal Range 0.48 -2.4 v (4-20 mA across a 120 n 0.02% tolerance resistor) (Refs. 4.4.2, 4.4.3)

Accuracy (12 bit) +/- 0.025% of full scale (Ref. 4.14)

Temperature Effect 50 ppm per °C =0.005%1°C (Ref. 4.14)

Drift Not stated Operating temperature range 0-55°C (32-131 °F)

Operating humidity range 20% to 80% RH, non-condensing Point Display 90 - 400 °F (Ref. 4.5.3, 4.5.4)

Calibration Information (Reference 4.5.3, 4.5.4)

Calibration As-Left Tolerance +/- 1.5 °F PPC point display Module 3 Location Information (Ref. 4.7, unless noted otherwise)

Location (Ref. 4.3) Unit 2: Analog Input Cabinet, Computer Room 301 Unit 3: Analog Input Cabinet, Computer Room 301 Normal Temperature 65 °F (min.)/ 72 °F (max)

Normal Pressure 14.7 psia Radiation mild environment These temperature limits are bounded by the manufacturer's specified operating limits so per Assumption 3.4 any temperature induced effects are considered to be included in the manufacturer's specified temperature effects. The humidity limits of the Computer Room 301 are not stated in Reference 4.7, however, per Reference 4.15 the computer room HVAC controls maintain a constant temperature and humidity. These cards have functioned successfully in this location for many years. Thus per Assumption 3.4 any potential humidity induced error effects are considered to be included in the manufacturer's specified accuracy.

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 27 of 35 Calibration Information (Reference 4.5.3, 4.5.4)

The temperature loop is calibrated by using a decade box of 0 - 200 ohms range with a minimum accuracy

+/- 0.082 ohms to simulate the RTD input to the temperature transmitter, and then reading the value in volts on the computer point display. The as*found and as*left voltages are converted to temperature and verified to a tolerance of+/- 0.4 °F.

Thus the calibration error is based on the +/- 0.082 ohm accuracy of the decade box used to read the input to the transmitter and the reading error of the computer point display. The reading error is the least significant digit of the display, which is +/- 0.001 volts. The computer cards are not adjusted. The maximum surveillance interval is taken as .30 months, based *On 24 months.including a 25% fate factor.

The +/- 0.4°F loop tolerance is applied in place of the vendor accuracy of the PPC point analog to digital input card, since it is larger than the card vendor accuracy (Assumption 3.8).

FW Inlet Temperature Note: All error values are +/-

Module 1: TE-2144A B, C, D, E, F (TE-3144A, B, C, 0, E, F)

Module 2: TT-2144A, B, C, 0, E, F (TE*3144A, B, C, D, E, F)

Module 3: PPC Point M057, M058, M059, M060, 8011, M019 CM357, M358, M359, M360, 8311, M319)

Module 2b: Gate card model RTP 7435/50 (021-5234) with AID converter model RTP 7436/21 14*bit AID Module 1: TE*2144A, B, C, D, E, F (TE-3144A, B. C, D, E, F) Value Units a Pvco 22-4079-4.1*12.75 RTD 100 n Platinum, dual, 3*wire (Ref. 4.3)

Uooer calibrated range 400 OF Lower calibrated range 90 OF Input span {400-90) °F (Ref. 4.3) 310 OF Output span: approx. 65 ohms, varies by TE to match 90 to 400 °F 65.005 ohms

=

Accuracy= A1= 0.25%SPAN 0.25%*310°F 0.7750 OF 2

=

Drift= 01 A1 (Assumption 3.7) 0.7750 OF 2

=

PMA O; PEA 0 =

Module 2-TT*2144A, B, C, D, E, F (TE*3144A, B, C, D, E, F) Value Units a Rosemount Model 3144 Digital Accuracy= DA= 0.18°F 0.18 OF 2

=

DIA Accuracy = DAA ::: 0.2% span 0.2%* 310°F 0.62 OF 2

Accuracy A2 DA + DAA 0.8 OF 2 Stability (drift)= greater of 0.1% rdg or0.1°C, for24 months

=

02' = larger of 0.1 %*400 °F 0.4 °F or 0.1°C*9/5 = 0.18 °F 0.4 OF 2

=

take as 2 intervals to cover 30 months: 02 SQRT(2*D2'"2) 0.5657 OF 2

=

Temperature Effect TE2 0.0015°C + 0.001 % span per 28°C change in ambient, taken over 65 to 72°F as:

=

TE2 (0.0015°C)*(9°F/5°C) + 0.001%*(310°F)*(72-65°F)/(28°C*(9°F/5°C)) 0.0031 OF 2 Power Supolv Effect neQliqible per Assumption 3.3

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 28 of 35 Module 3

PPC Point Al Card for M057, M058, M059, M060, 8011, M019 (M357, M358, M359, M360, 8311, M319) Value Units a RTP Analog Input Card VA3 =Accuracy= 0.025% full scale (Ref. 4.14) 0.1 OF 2 TE3 =Temp Effect= 50 ppm full scale/°C taken over 65 to 72°F as:

0.005%*(400 °F)*(72 - 65)°F*{5°C/9°F) (Ref. 4.14) 0.0778 OF 2 Drift= D3 = A3 (Assumption 3.7) 0.1 OF 2 Calibration Setting Tolerance= CST3' = 0.04 °F 0.4 OF 3 CST3 as 2a value: CST3 = CST3'*2/3 0.2667 OF 2 Accuracy= A3 = MAX(VA3,CST3) (Assumption 3.8) 0.2667 OF 2 Resistor Tolerances

=

R1 = resistor 1 tolerance = 0.02% 0.02%*400 °F (Ref. 4.4.2, 4.4.3)

(Conservatively taken at uooer ranQe value of 400°F) 0.08 OF 2 Calibration Error (Refs. 4.5.3 4.5.4) 1 Value Units a Module 1 lnout Calibration Error: CLI1 = 0 Module 1 Output Calibration Error: CL01 O =

=

Module 1 Calibration Error: CC1 SQRT(CL11"2 + CL01"2) 0 = 0 OF 2 Module 2 Input Calibration Error: CLl2 = 0.082 ohms*(310 °F}/(65 ohms) 0.391 OF 2 Module 2 Output Calibration Error: CL02 o =

Module 2 Calibration Error: CC2 = SQRT(CLl2"2 + CL02"2) = CLl2 0.391 OF 2

=

Module 3 Input Calibration Error: CLI3 Jnput Error= O Module 3 Output Calibration Error: CL03 =Output Error= 0 0 OF 2

=

Module 3 Calibration Error: CC3 SQRT(CLl3"2 + CL03"2) = 0 0 OF 2 Loop Error Calculation Value Units a Loop Accuracy: LA= SQRT(A1"2 + A2"2 + TE2/\2 + A3A2 + TE3/\2 + R1"2) 1.1507 OF 2 Loop Drift: LO= SQRTCD1"2 + 02"2 + 03"2) 0.9647 OF 2

=

Loop Calibration Error: LC SQRT(CC1 "2 + CC2"2 + CC3"2) 0.3910 OF 2 Temperature Channel Error Calculation Value Units a

=

Loop error al SQRT(LA"2 + LC"2 + LD"2) 1.5517 OF 2

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 29 of 35 7.4 Feedwater Mass Flow Uncertainty in the PPC Looo configuration The measured values of the differential pressure across each feedwater nozzle and the reactor feed pump discharge temperature of each loop are inputs used in the PPC to calculate the mass flow of each nozzle.

The loop configuration is shown below (Refs. 4.1 O and 4.11 1 rnput 2.1.1 ):

Feedwater Differential Pressure 0-hs lnwc ~~~~--------------~ Calculated 8044 (8344) Mass Flow 8045 (8345) 0-8.000 8046 (8346) Mlbm/hr 8018 (8318)

Feedwater Temperature 8019 (8319) 90-400°F - - - - - - - - - - - - - - - - 8020 (8320)

M058, M060 (M358, M360)

M057, M059 (M357, M359) 8011, M019 (8311, M319)

. RFP Mass Discharge Flow* PPC Point 8018, 8019, 8020 (8318, 8319, 8320)

- This is a calculated point based on two variables: the feedwater flow differential pressure input and the

feedwater inlet temperature (Design Input 2.2 1 based on References 4.10 and 4.11).

Within the PPC, the 30 Monicore converts the differential pressure input to mass flow as follows:

Unit2:

A Loop: =

8018 NSCFW001*8516

SQRT(8044) 8 Loop: 8019 = NSCFW002

5517

SQRT(B045)

C Loop: 8020 = NSCFW003

5518

SQRT(B046)

Unit3:

A Loop: 8318 = NSCFW301*5816

5QRT(B344)

B Loop: 8319 =NSCFW302

8817

SQRT(B345)

C Loop: 8320 = N5CFW303

8818

SQRT(B346)

GenericaJly, Bxxx =N8CFWxxx

Sx1x *SQRT (Bx4x) Eq. 7.4.1 Where:

Bxxx is feedwater mass flow point, in units of Mlbm/hr Bx4x is the differential pressure point, in units of inwc 5x1 x are unitless scaling factors determined in Ref. 4.11 as:

Unit 2 5516 = 10.27333 Unit 3 5816 = 10.25728 5517 = 10.34251 5817 = 10.37076 S518 = 10.23560 8818 = 10.21455 N5CFWxOx is a density correction in the 30 Monicore, based on difference between the nominal feedwater temperature and the measured reactor feed pump discharge temperature, as:

NSCFWxOx = FWC2*(1.0 +OT* (FWC4 + OT* FWC5)) Eq. 7.4.2 Where: DT=TFW-FWC Eq. 7.4.3

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 30 of 35 OT= difference between measured and nominal feedwater temperatures TFW = measured feedwater temperature for the loop. TFW is the average of the two loop temperature points if both points are good; or TFW is equal the single good point if only one is good. The temperature points are:

Unit 2 Loop A: MOSS, M060 Unit 3 Loop A: M358, M360 Loop 8: M057, M059 Loop 8: M357, M359 Loop C 8011, M019 Loop C: 8311, M319 FWC2 = 3.09400E-02 FWC3 = 376.1°F FWC4 = -3.35720E-04 FWC5 = -4.14750E-07 All of these numbers are constants, except for the measured differential pressure (8044, 8045, 8046, 8344, 8345, 8346) and measured feedwater temperature {TFW). Thus the feedwater mass flow is calculated as a function of two variables, feedwater differential pressure and feedwater temperature.

First, based on Eq. 7.4.1, in order to simplify the written nomenclature before taking partial differentials, let mass flow be represented as:

Eq. 7.4.1*1 Where:

M =mass flow 8018, 8019, 8020, 8318, 8319, 8320 (variable)

N =density correction NSFW001, NSCFW002, NSCFW003, NSCFW301, NSCFW302, NSCFW303 (variable)

S =scaling factor 8516, 8517, 8518, 8816, 8817, 8818 (constant) h =differential pressure 8044, 8045, 80461 8344, 8345, 8346 (variable)

Let Eq. 7.4.2 be represented as: N =C2*(1.0 + D * (C4 + D *CS)) Eq. 7.4.2*1 and-Eq. 7.4.3 be represented as: D=T-C3 Eq. 7.4.3*1 Where:

C2 = FWC2 (constant)

C3 =FWC3 (constant)

C4 = FWC4 (constant)

CS = FWC5 (constant)

D = DT = feedwater temperature difference (variable)

T = TFW = measured feedwater temperature (variable)

Substituting Eq. 7.4.3.. 1 into Eq. 7.4.2.-1:

N = C2 * (1.0 + (T-C3) * (C4 + (T- C3)*C5))

N =C2 * (1.0 + C4 * (T-C3) +CS* (T - C3)2) Eq. 7.4.4-1 Substituting Eq. 7.4.4-1 into 7.4.1-1:

M = C2 * (1.0 + C4 * (T - C3) + CS * (T - C3) 2 )

S

h1/2 Eq. 7.4.5*1

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 31 of 35 Based on Equation 6.6-31 the uncertainty in feedwater mass flow due to the effects of temperature and differential pressure measurement uncertainties is:

oM 2 aM 2]112 UM = [ (aT

crT) + (ah

crh)

This may also be expressed as:

uM = [uMTZ + uMh2r12 Eq. 7.4.6 Where UMr is the uncertainty in mass flow due to the effect of temperature measurement uncertainty and UMh is the uncertainty in mass flow due to the effect of differential pressure measurement uncertainty.

First these two uncertainty effects are determined using bounding conditions for each case in order to determine the maximum error at nominal feedwater flow for MUR operating conditions.

Effect of Temperature Measurement Uncertainty:

Taking the partial differential of Eq. 7.4.5-1 with respect to temperature:

1 iJMI iJT = C2

s * {C4 + 2

cs * (T - C3))

h h The uncertainty in feedwater mass flow due to the effect of temperature uncertainty is:

UMT'" [(~~

CfT fr Substituting the partial derivatives from above:

1 12 UMT-= [(C2

S * (C4+ 2 *CS* (T-C3))

h /z

crt)2}1

Substituting the original constants and variables:

1 UMT -= [( FWC2

Sxlx * (FWC4 + 2

FWCS * (TFW - FWC3)) * (Bx4x) h

crTFW )2f'2 Eq. 7.4.7 Solving Equation 7.4.7 for Unit 2 and Unit 3 using (from above):

=

FWC2 3.09400E-02 = 0.03094

FWC3 = 3.76100E+02 = 376.1 FWC.4 = -3.35720E-04 FWC5 = -4.14750E-07 Unit 2: 8516=10.27333, 8517=10.34521, 8518 = 10.2356;

=

so Sx1x = S51x 10.35 to bound Unit 2 values

=

Unit 3: 5816=10.25728, 8817 10.37076, 8818 = 10.21455;

=

so Sx1x SB1x = 10.38 to bound Unit 3 values TFW = nominal feedwater temperature at MUR conditions = 383.4 °F

=

Bx4x hR = nominal (rated) differential pressure, from Section 7.2

= 304.20 inwc (Unit 2); 302.40 inwc (Unit 3) arFW = feedwater temperature measurement error=+/- 1.5517 °F (Section 7.3)

The uncertainty in mass flow due to the temperature measurement uncertainty, based on Eq. 7.4.7:

1 )2)1/2 UMT = [(FWC2

Sxlx * (FWC4 + 2

FWCS * (TFW- FWC3)) * (Bx4x) /2

crTFW

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 32 of 35 For Unit 2:

UMT2 = [(0.03094*10.35 * (<-3.35720£-04) + 2 * (-4.147SOE- 07 ) * {383.4- 376.1)) * {304.20) 112 2]1/2

1.5517)

UMTz = +/- 0.002962 Mlbm/hr For Unit 3:

1 UMT3 = [(0.03094

10.38 * ((-3.35720E-04) + 2 * (-4.14750E-07 ) * (383.4 - 376.1)) * (302.40) 12 2]1/2

1.5517)

UMT 3 = +/- 0.002962 Mlbm/hr Effect of differential pressure measurement uncertainty:

Taking the partial differential with respect to differential pressure:

BM/ah=~*

. 2 1

C2

S * {1.0 + C4 * (T- C3) +CS * (tT- C3) 2 )

h- /2 The uncertainty in feedwater mass flow due to the effect of differential pressure uncertainty is:

BM 2]1/2 UMh = [ (ah* ah)

Substituting the partial derivatives from above:

2]1/2 UMh = [ (z1

C2

S * (1.0 + C4 * (T- C3) +CS* (T- C3) 2

)

1

h- h

crh)

Substituting the original constants and variables:

1 2]1/2 UMh = [(i

FWC2

Sxlx * (t.O + FWC4 * (TFW- FWC3) + FWCS * (TFW- FWC3) 2) * (Bx4x)-h

O'ax4x)

Eq. 7.4.8 Solving Equation 7.4.8 for Unit 2 and Unit 3 using values from above and:

aex4x = feedwater differential pressure measurement error, from Section 7.2

= +/- 19.2182 inwc (Unit 2): +/-.20.4523 inwc (Unit 3)

The uncertainty in mass flow due to the differential pressure measurement uncertainty:

For Unit 2:

UMh = [ (~

FWC2

Sxlx * (1.0 + FWC4 * (TFW - FWC3) + FWCS * (TFW - FWC3) 2) * (Bx4xf11z 2]112

O'Bx4x)

CALCULATION NO. PM*1209 REVISION NO. 0 PAGE NO. 33 of 35 G

uMh2 = [

0.03094 *10.35 * (1.0 + 03.35720E-04 * (383.4 - 376.1) + (-4.14 750E- 07) * (383.4 - 376.1) 2 )

1 2]1/2

(304.20)- h

19.2182)

UMh2 = +/- 0.1760 Mlbm/hr For Unit 3:

UMh3 = [(~

0.03094

10.38 * (1.0 + 03.35720E-04 * (383.4 - 376.1) + (-4.14750E- 07 ) * (383.4 - 376.1) 2 )

. 2]1/2

(302.40) -11i

20.4523)

UMh3 = +/- 0.1884 Mlbm/hr Total uncertainty in mass flow due to both the temperature and differential pressure measurement uncertainty:

Recalling Eq. 7.4-6 from above Um = [ Umt 2 + Umh 2]1/2 Eq. 7.4.6 Combining the uncertainty in mass flow due to temperature measurement uncertainty and differential pressure measurement uncertainty, based on the values determined above from Equations 7.4. 7 and 7.4.8.:

For Unit 2: Um 2 = [(0.002962) 2 + 0.1760 2 ] 112 = +/- 0.1760 M~~m For Unit 3: Um 3 = [(0.002962) 2 + 0.18842]112 = +/- 0.1884 M~~m By inspection is can be seen that the temperature measurement error has an insignificant effect on the overall mass flow measurement .error, because the effect of the differential pressure measurement error is over 59 times greater. Thus the error contribution due to temperature measurement may be neglected and the error in mass flow is based entirely on the error in differential pressure measurement.

Dividing by single element mass flow (FR = 5.4813 Mlbm/hr from Section 7.2) to put in terms of percent of flow:

For Unit 2: Um2 =(0.1760 Mlbm/hr) I (5.4813 Mlbm/hr) =+/- 3.21 of nominal flow For Unit 3: Um3 = (0.1884 MJbm/hr) I (5.4813 Mlbm/hr) = +/- 3.44% of nominal flow

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 34 of 35 7.5 Feedwater Mass Flow Total Uncertainty The individual uncertainties for nominal feedwater flow at MUR conditions as determined in Sections 7 .1 through 7.4 are:

Section Parameter Unit2 Unit3 7.1 Single Feedwater Nozzle Uncertainty +/- 2.95% of flow +/- 3.18% of flow 7.2 Feedwater Flow Differential Pressure Measurement Uncertainty :t 19.2182 inwc. +/- 20.4523 inwc 7.3 Feedwater Inlet Temperature Measurement Uncertainty +/- 1.5517 °F +/- 1.5517 °F 7.4 Feedwater Single Loop Mass Flow Uncertainty in the PPC, :1: 0.1760 Mlbm/hr +/- 0.1884 Mlbm/hr based only on the uncertainty of the differential pressure measurement +/- 3.21 % of flow +/- 3.44% of flow Table 7.5-1 Feedwater Mass Flow Uncertainties

CALCULATION NO. PM-1209 REVISION NO. 0 PAGE NO. 35 of 35

8.0 CONCLUSION

S For Peach Bottom Units 2 and 3, the error in feedwater mass flow as determined in the PPC for a single feedwater flow loop is based entirely on the error of the differential pressure measurement across the nozzle. For Unit 2, this uncertainty is+/- 0.1760 Mlbm/hr1 or+/- 3.21 o/o of nominal feedwater flow for MUR operating conditions. For Unit 3, this uncertainty is +/- 0.1884 Mlbm/hr, or +/- 3.44 % of nominal feedwater flow for MUR operating conditions.

These values are provided for input to the Cameron calculations that will determine the overall uncertainty in the Peach Bottom Unit 2 and Unit 3 CTP Calculation for the MUR Uprate. There are no specific acceptance criteria:

If future modifications replace components in any of the analyzed loops, the calculated uncertainty results will remain bounding as long as the replacement components are at least as accurate as those analyzed herein. If the calibration equipment is replaced or calibration processes or procedures are modified in the future, the calculated uncertainties remain bounding as long as the calibration equipment is at least as accurate as what is analyzed herein, and the calibration process maintains the same or smaller as left tolerances.

PM-1209 Revision 0 Attachment A Page A 1 of A3 Patricia Ugorcak From: Schoenknecht, Karl A:(BSq < karl.schoenknecht@exeloncorp.com >

Sent: Thursday, April 06, 2017 12:06 PM To: Cutler, Kenneth E:(GenCo-Nuc)

Cc: Hamm, Kelly Eugene:(GenCo-Nuc); Patricia Ugorcak

Subject:

<EXTERNAL> RE: Input for FW flow equation in PPC Ok, Here is something I wrote up using the Unit 3 points describing the implementation in the computer. It does not describe how the redundancy works (the A points), but maybe this is the confirmation you are looking for?

Karl 8318: 3A Feedwater Mass Flow {Mlb/hr) 8318 = NSCFW301

5816

SQRT(B344)

[If the value of 8318 goes below constant 5863, 8318 is clamped to O Mlbs/hr]

NSCFW301 =3A F/W FLO CORRECTION FACTOR, calc'd Jive by 3DMONICORE B344 (A2713) 3A Feedwater delta-P 5816 =constant (10.2400) 5863 =constant ( 0.70 Mlb/hr) 8319: 38 Feedwater Mass Flow (Mlb/hr)

=

8319 NSCFW302

5817

SQRT(B345)

[If the value of 8318 goes below constant 5863, B319 is clamped to O Mlbs/hr]

=

NSCFW302 38 F/W FLO CORRECTION FACTOR, calc'd live by 3DMONJCORE 8345 (A2714) 3B Feedwater delta-P

=

5817 constant (10.3237 )

=

5863 constant ( 0. 70 Mlb/hr) 8320: 3C Feedwater Mass Flow (Mlb/hrl 8320 = NSCFW303

5818

SQRT( B346)

[If the value of 8320 goes below constant 5863, 6320 is clamped to O Mlbs/hr]

=

NSCFW303 3C F/W FLO CORRECTION FACTOR, calc'd live by 3DMONICORE B346 {A2715) 3C Feedwater delta-P 5818 = constant (10.3544 )

5863 = constant ( 0. 70 Mlb/hr)

From: Cutler, Kenneth E:(GenCo-Nuc)

Sent: Thursday, April 06, 2017 1:00 PM To: Schoenknecht, Karl A:(BSC) <karl.schoenknecht@exeloncorp.com>

Cc: Hamm, Kelly Eugene:(GenCo-Nuc) <Kelly.Hamm@exeloncorp.com>; Patricia Ugorcak <pugorcak@enercon.com>

Subject:

RE: Input for FW flow equation in PPC Karl, this is for MUR (Appendix K round 2), not DFW. MUR would not be changing the formulas. Here is more clarification on the request:

Kelly, 1

PM-1209 Revision 0 Attachment A Page A2 of A3 What I most need is an input that says that points 8018, 8019, 8020, B318, B319 and 8320 are determined in the PPC from points B044, 8045, 8046, 8344, 8345 and 8346 as follows:

For Unit 2: 8018 = NSCFW001 *SS16*SQRT(B044) A Loop 8019 = NSCFW002*5517*SQRT(B045) B Loop 8020 = NSCFW003*SS18*SQRT(B046) C Loop For Unit 3: =

8318 NSCFW301 *S816*SQRT{B344) A Loop

=

8319 NSCFW302*S817 111 SQRT(B345) B Loop

=

B320 NSCFW303*5818*SQRT(B346) C Loop S-102-VC-25 and -31 define how the NSCFW0{3)0x terms are ca.lcu.lated in 30 Monicore, so that part is covered.

EE-0029 determines the 55(8)1X terms, based on the Unit 2 tracer tests from 1992 and the cross flow ultrasonic testing from 1999. Even if they change when EE-0029 is revised, that shouldn't affect the uncertainty determination. But if there is a better input for those values than the current revision of EE-0029, then I should use it. What matters most is a source that states how the 8018 type mass flow points are calculated from the B044 type differential pressure points.

I hope this clarifies the request. I can call you after 2 today to verify.

Patty Ken Cutler, P.E.

Senior Engineer, Electrical/l&C Peach Bottom Atomic Power Station (717)-456-4590

.=:::-- Exelon Gt'rn~rat110n.

From: Schoenknecht, Karl A:(BSC)

Sent: Thursday, April 06, 2017 12:56 PM To: Cutler; Kenneth E:(GenCo-Nuc)

Cc: Hamm, Kelly Eugene:(GenCo-Nuc); Patricia Ugorcak

Subject:

RE: Input for FW flow equation Jn PPC

Ken, Is this for Digital Feedwater control upgrade? I had a strange email exchange with Driscoll on this.

Anyway, I would not call this description 100% accurate. The formulas look okay but the description of the redundancy is off.

Unfortunately I don't have a written description, but would be happy to answer questions.

Will these calcs be changed by the mod?

Karl From: Cutler, Kenneth E:(GenCo-Nuc)

Sent: Thursday, April 06, 2017 12:37 PM To: Schoenknecht, Karl A:(BSC) <karl.schoenknecht@exeloncoro.com>

2

PM-1209 Revision 0 Attachment A Page A3 of A3 Cc: Hamm, Kelly Eugene:(GenCo-Nuc) <Kelly.Hamm@exeloncorp.com>; Patricia Ugorcak <pugorcak@enercon.com>

Subject:

FW: Input for FW flow equation in PPC Karl, would it be possible for you to validate the information Patty is asking about?

Ken Cutler, P.E.

Senior Engineer, Electrical/l&C Peach Bottom Atomic Power Station (7.!!l:-456-4590

~ ExelonGenerntio~~.

From: Patricia Ugorcak [ma!lto:ougorcak@enercon.coml Sent: Thursday, April 06, 2017 10:01 AM To: Hamm, Kelly Eugene:(GenCo-Nuc)

Cc: Jim Kyer; Larry Lawrence; Cutler, Kenneth E:(GenCo-Nuc)

Subject:

[EXTERNAL] Input for FW flow equation in PPC

Kelly, Attached is Att 8.1 from PM-10S1 Rev. 0. It includes the equations used by the PPC for conversion of the differential pressure input points {6044, 8045, 8046 type) to mass flow (8018, B019, 0020 type). The Info is highlighted in yellow on pages 3 and 4. ls there a way I can get a more modern Input for this Information? Perhaps from someone in a computer group or the PPC system manager?

Patty Patricia Ugorcak Senior l&C Engineer 2056 Westlngs Avenue Ste. 140 I Naperville, IL 60563 Direct: 630.864.3638 I Fax: 630.864.3602 pugorcak@enercon.com I www.enercon.com

.: ~ ~~> Pltaae conaiderth* en*oironmunt berore printing thia e-mail.

~;~ ENERCON If ' ' ' : *'I ~ I ... I This Email message and any attachment may contain information that is proprietary, legally privileged, confidential and/or subject to copyright belonging to Exelon Corporation or its affiliates ("Exelon"). This Email is intended solely for the use of the person(s) to which it is addressed. If you are not an intended recipient, or the employee or agent responsible for delivery of this Email to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this Email is strictly prohibited. If you have received this message in error, please immediately notify the sender and permanently delete this Email and any copies.

Exelon policies expressly prohibit employees from making defamatory or offensive statements and infringing any copyright or any other legal right by Email communication. Exelon will not accept any liability in respect of such communications. -EXCIP 3

Select Tables and Figures from ANSI/ASME PTC 6 Report 1985 PM-1209 Revision 0 Attachment B Page Bl of 84 TABLE ,.10 9ASE UNClERTAINTIES OF PRIMARY FLOW MEASUREMENT

~

I" li*id Sti"rhHltd Stum ~.t l.nst 25° Sui1te1hNI)

Flow N0zzl~ llawNoul' Throat PipeW.all Throaf P'f~W(\11

11111 1'.111e Ul'IC*!f't.111.ftlt.~, U.,% lap T.a.p Orifice T-1p Tap OriSeti Ci'oup 1 - Cilibr111rd Fklw 5Ktlo111 A MeeUng code- requirements 0.15 0.2S 0.25 0.23 0.3S 0.45 INOlit-(l)J [Nll1e (4)) [Nut~ (4J] [Not~ (4)] [l'-ifo1q (41] (Not~ (_.I)

B Calibri11ed lmmedl.a1ely b.eloreo te't lnd 0.2$ 0.50 0.60 0,50 0.15 1.10 inspected idler test, coeffident cul"\Je i.91(* rapo1411cd c Calibra1ed before lnstallalion and 0.35 0.f..O 0.80 0.10 1.0S 1.65 inspected befote and af1er test assuring no \risl ble M me.asur.abl~ c::ha.nges. ii\ th~

flow ~lement D Calibrated before permanent installation 1.25 1.25 1.55 '1.60 1.70 2.30 ind in,talled after initial iru:s.hing fN01e (1l]

E Calibrated before petnunent iirlstallatiot11 2.50 2.50 l.00 vs 2.80 3.?0

[Notf:s (1) and 42)1 Growp 2 - UncaRbrilfed Flow Sec:l.5oMs.

F ln$pi:!'t..'1.~ iment."Cliiltely before a.nd a.fter 0.8() 2.00 1.00 1.:!f) 2.SO 2.00 test

{; lnsp~ct<<I immediately beru rt! tll!!ict t.1S l.SO :uo 1.SO ].00 3.00 H ln11p~ed before pl:'rmanc:f'lt lnst.allation ::uo 3.2U 3.20 l.00 l.70 4.20 (Notes Cl) and 42))

I No inspection .and perminent iMlallatlon s.,., Par. 4.16(a) (1), 11cm I GENf~Al NOTf~ Ovetall uncerta.intr of flow sections:

With no now scr~ight~~t!r = J(u~f + (Ui.~ 2 + <V11i> + lUJ>ur

=

WUh. ~ flow $1raighttner .J<U,'1' + (U~z + lUu,)1 + tUt~n)l + (U0 s,il:1 1

Whonr U1 is from ehis tabte, Uu~*.ri is from fig* ...s, LJd. is imm Fig. 4.6, Um is from fig. 4.7, Uu, \i ir~cn Fig, 4.8, and Uosc is from fi.g;.

4,.9.

NOTE5~

(1) Good ~tar ehfrristry, no after test inspection, less than six mon*hs in setvlce Csee Par. 4.17J.

(2) Reason1b1e usu ranee that minima.Ida.mag~ v.o.as caused 10 AllW eleme-n1 durina inlli:tl tlushing.

(l) 0.1.5~ per1.-ln$ to flow sectiOn!li l~ated in the lowvnempera.lure part-oi 'hf! qicle. The 0.1S" mily Increase to 0.25" when *he fltw.* sec:Uon is located in 1he hlghet ten1peracure part or the q1rde-, such as iB 1he boiler feedw.ater Hne* downstream of the top hl!!ater.

('4) lntottnation ruEativo to the conmucHon, calibration, ind lnstaHation al 01her flow-measuti*'8 devlc:e!'i ls describe:d in ASME Pr<:

19.S-197.2*.Although thesedevlC$9 are not r<<Ol'nmended f.or tht* rne~:sur~montot primuyflow, nu:y maybe use<J ;f 'hey conform to th!' general NqUiremenU. e>f Par. -'1.22 of th* Code with the followlng elC<~Cions:

fl} Fot the requlrf!mem or P~t. il.22(i) cf ih-e code-, ,h& i3 r*tit* shi111 br. limited 'o 1lie range 0,25 to 0.50 for Wilt tap nozzl~s. and

'lel'l* i,rrii. 41ilid O.JO to 0.60 *or orifices, Cb) For Che rcquiri:mt!nt of P.ar. 4.22{d> of the Code, 1he appropriate reference coeffi<ient for tnuc,ual device gi..*en In PTC 19.5 snail be used. The p.arE~ 10 a 1est $hauld bectime ~,;iimillar wltti tfl.co con1encs of PTC 19,5 ~irdl11g tnese devl(es.

SelectTables and Figures from ANSl/ASME PTC 6Report1985 PM-1209 Revision 0 Attachment B Page B2 of 84 1.1\HlE .&. 11 MIN1MUM $1AAtGHT lENCTH OF UPSTREAM f'IPE FOR oamcE Pl.ATES ANO FLOW NOZZ.t~ FLOW SECTIONS WITH NO fLOW STWCHTiNERS (Minimun~ Straight lengths of Plpa Required S~twcen Various Fittings LocaEed at *nrer and Oudea of the Primarv De\'lceJ' and Device Itself (based on information in ASMI: MFC.:-3M*1965 and ASME

p*rc 19,5.1912>.1

-**--------..,.-----~-----~-------

1 Col""'" 1 Column :2 On lrtll!'ll Side I

ol Column 3 Prh1'Nll')' Dti=vicl!

j Column 4 i Column S Column 6 Column'l 1~1.~s~jf~s "" ilmf

[

~.1 I

Sin1lc ~ dog.

Be11d or Tt".t'

PLlnei,

$4:p;a,~ti:d by 1 Cl Dlai1M1e~rs ~ Two 90 dlfl..

(fltlw fr'1m Twa 4JO deg. cl Stt..iilgllt 1. Elll Nat IA V.af\.-t or OnOudet

~ D~n,e1e.. Ofle Bt MlCh Ells In Sime- Pipe ~ Sam!!' Pla.qe ~ R~dll('!ft itnd Rqul~lor Side (For A.11 i---lli-ilt_ia_*--11---0-ilt_r)_ _t--_,.._ai"'_e-_--t___1N_o"'_1_e_O_lJ_~*_ _ LN.~~~ rJJJ L"f~.~nden [NoCe Oil

' * -**.:. .t11........ *1o' 1nre<~

- ""-LoW:* ~* , **'

O.fO 0:15 6

6 8.5 u..s 6

6 I ~: 6 16.S 17 2.5 2.5 0.20 6 l}.5 6 r 14.5 ,: : '18" 2.5 0.25 (, 3.S 6 ~ 15.S ! 1U 3 0.30 6 e.s 6 1(1 ' i j

"19,$ 3 0.35 6 6.S {) 11 2.0.S 3 0.40 6 R.S 6 1fl 21 3..S

~

0.45 "-~ 1CJ.S 23.S l.S O-'m 7 ID i ..5 21 i 2S 3,S Cl.S3 H.5 8.5 22.S 8 27 3,S

~:__i~-~-*.______ s ~l~-~ - - - ~-~- *~.-. -I)'- -~- r.~* ~-'

CJ.~

~

(J.()(t 0.65 l1.5 16 (J.71J 1"1 1~1 CJ.75 16.5 21.S GENERAL NOTf.S:

<al .All str~~~ht ,engths are Cl'lpressed :as multiple!i n* pipe diamt'1~r D ilnd ~r~ m('iJ!-U r~(1' f'mm th~ up~tre..tn-cmd rl1~ inrt:!I sec.:li01l.

(b) lhe radius of c.:us:valurc of ii. bend or c1bow shall not be "SS th&1.n 0.7~ 1imc::s the pi~ di4'm<i1c:r ().

t-\OTE.S:

[1) If this le1,g1h is less 1hano 1.0 diamcHiCrS, C.:olurnn l ~halt .lf)flly.

~ZI i( tt~ 1v.'O ells in O;tumn 4 .,1r*e d~>sely &')r'<<edti!d l>~* a thltd ell not In 1he same pl.ant as the sei.:ond e-ll, ch~ ~,ipir1g tP.q.,lrem~nls

-shown by Column 4 !\hc)uld Ile~ duubh~d.

13) The v41I"'~ ()r rc.guleltor in Cn1umn 6 r1~tricts thf!i flt:~w; hnYii"t.."1er, a widl!! ope1t {;ate \*.tlve fll' plug vnrvc may be con'.!ide-rcd as nol er~a1ing any !ierinu!i di~1u,bance. and i1 ma~* be located according tr'I rite requit~1tmnts or cha firdng *lr.ecedlH9 ii~ .a... permitted in Col U4'11n l. 2. ~. or 4.

Select Tables and Figures from ANSI/ ASME PTC 6 Report 1985 PM-1209 Revision O Attachment B Page B3 of 84

~_, 2.0

~ 1 .. ()_

-~

....... I i

.s -....

1.Ei I

> 1:. 0.5 I J ~

1.0 .. I 1.0 U* 2,0 A*tio 1s,.*uht ue**reim urt!!t' L*r'ltrl*h r.torn Tabl* ** 1't GENERAL NOTE: CUf'Vff .,, for Uow Hedon 1r111191menb whtilre Ofl!y modl111t1 UPI*'"'" di1,urt>.nc1t tr* HPIClld .... P*r*** 16t.

HG. '..5 MINIMUM STIAIGHT IUN OF UPSHEAM Plrf A.RH now DISTURIANCI, NO now SUAIGHJENH:

2.0

~

~~.P:___.

.Jf.e'~~.."4 ..

~~ ...

........ ~-

i."'"

0 o.* 0.5 o.. ~.7 0.1

"-riO FK:. 4., - IATKl EfHCl'

Select Tables and Figures from ANSl/ASME PTC 6Report1985 PM-1209 Revision 0 Attachment B Page 84 of 84 1.6 . . . . . . .. I . .- -

~

...J GENERAL NOTE:

For sections wi1h ar withoui flow nr1i9h\tniers : .

and up to 0.75.a? ratios *

~

~ 1.0

)

~

...>c

'j 0.5

-- ~--

~

~~

G g r--..

')

0 0.8 0.9 1.0 1.5 2.0 2.5 3.0 Straig1'1t Downstream Length Ra Ho Length Ftom Column 7. Table 4.11 FIG. 4.9 EFFECT OF DOWNSTREAM PIPE LENGTH

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Proven field performance and reliability

Commitment to continuous improvement

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Two-year stability.of0.1%

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These Integral orifice flowmeters eliminate the Inaccuracies that Rosemount 1199 Diaphragm Sea1s become more pronounced in small orifice line installations. The Provides reliable, remote measurements of process pressure and completely assembled, ready to install flowmeters reduce cost and protects the transmitter from hot, corrosive, or viscous fluids. simplify installation.

2

Product Data Sheet Calculation PM-1209 Revision O 00813-0100-4360, Rev JB Attachment C Page 03 of 028 March 2010 Rosemount 1151 Specifications PERFORMANCE SPECIFICATIONS (Zero-based calibrated ranges, reference conditions, silicone oll fill, 316 SST Isolating diaphragms for HART 4-20 mA protocol.}

Accuracy Output Model Accuracy Specification and Span Output Code S Ranges 3 through 8 for DP and GP: +/-0.075% of calibrated span between 1:1 to 10:1 of URL Ranges 4 through 7 for HP

+/-[0.02(~~~)-o.1 ]% of calibrated span between 10:1 and 50:1 of URL Square Root Mode +/-[0.2 + 0.05 x URL]% of calibrated flow span for all spans span All other ranges and transmitters +/-0.25% of calibrated span for all spans Output Codes

Ranges 3 through 5 for OP and GP :1:0:2o/o of calibrated span for all spans E, G, L, and M PS Option: Ranges 3 through 8 for DP :t.0.1% of calibrated span for> 10 inH 20 and GP, all HP and all LT All oth~r ranges and tran~mltters ~.2~~ of cal!brated span for all spans Stability Output Code Model Specification s Ranges 3-8 +/-0.1 of URL for 2 years EandG Ranges 3-6 :1:0.2 *of URL for 6 months All other ranges +/-0.25 of URL for 6 months All ranges +/-0.25 of URL for 6 months Temperature Effect Output Code Model Specification s DP/GP Ranges 4-8, HP Ranges 4-8 Zero Error= :1::0.2% URL per 100 °F (56 °C)

Total Error= +/-(0.2% URL+ 0.18% of calibrated span) per 100 °F; double the effect for other ranges and transmitters e; G, L, and M Ranges4-0 Zero Error= :t0.5% URL per 100 °F. .

Total Error = t(0.5% URL + 0.5% of calibrated span) per 1oo °F; double ~e effect for Range 3.

Line Pressure Effect Model Zero Error Span Error DP Range 4 and 5 +/-0.25% of URL for 2,000 psi (13790 kPa), Correctable to +/-0.25% of Input reading per 1,000 psi (6895 kPa) correctable through rezeroing at line pressure.

DP Range 3 :l:0.5%, eorrectable through rezerolng ~t line Correctable to +/-0.5%~ of Input reading per 1,000 psi (6895 kPa) pressure. .

DP Transmitters +/-0.5%, correctable through rezerolng at llne Correctable to +/-0.25% of Input reading per 1,000 psi (6895 kPa)

Ranges 6-0 pressure.

HP Transmitters +/-2.0% of URL for 4,500 psi (31027 kPa). Correctable to +/-0.25% of Input reading per 1,000 psi (6895 kPa).

A!I Ranges correcta~le throug.h ~ezerolng at llne pres~ure*.

3

Calculation PM-1209 Revision O Product Data Sheet Attachment c 00813-0100-4360, Rev JB Page C4 of C28 Rosemount 1151 March 2010 Vibration Effect Short Circuit Condition (Low Power Only) 0.05% of URL per g to 200 Hz In any axis No damage to the transmitter will result when the output ls shorted to common or to power supply positive {limit 12 V).

Power Supply Effect Output Codes S, E, and G EMl/RFI Effect Less than 0.005% of output span per volt Output shift of less than 0.1% of span when tested to SAMA PMC Output Codes L, M 33.1 from 20 to 1000 MHz and for field strengths up to 30 Vim.

Output shift of less than 0.05% of URL for a 1 V power supply Mounting Position Effect shift Zer:o shift.of .up .to 1.lnH20 (0.25 l<Pa.).

Load Effect With liquid level diaphragm In vertical plane, zero shift of up to 1 Output Codes s. E, and G lnH2.0 {0.25 kPa). With liquid level diaphragm In horizontal plane.

zero shift of up to 5 inH 20 (1.25 kPa) plus extension length on No load effect other than the change In power supplied to the extended units. All zero shifts can be calibrated out No effect transmitter. on span.

Output Codes L, M Less than 0.05% of URL effect for a change In load from 1OOkO to infinite ohms.

FUNCTIONAL SPECIFICATIONS Service Liquid, gas, and vapor applications Range and Sensor Limits TABLE 1. Transmitter Range Availability by Model (URL =Upper Range Limit)

Range Code 1151 Ranges (URL} DP HP GP DP/GP/Seals AP LT 3 30 lnH2 0 (7.46 kPa) NA NA NA NA 4 150 lnH20{37.3 kPa) 5 750 lnH20 (186.4 kPa)

a 6

7

100 psf(689.5 kPaY

300 psi (2,068 kPa) 1,ooo psi (6.,895 kPa)

NA NA NA NA 9 3,000 psl (20,684 kPa) .NA NA NA NA NA

...... ' NA 0 6,000 psi (41~36~ kPa) NA NA NA NA TABLE 2. Rangeability S (DP and GP, SST, Range 3-8; HP SST, Range 4-7) s (All Others) * * * ***

E,'<3 L

M (1) Minimum span equafs the upper range limit (URL) divided by rangedown.

(2) Transmitter Is capsbfe of measuring from -URL to URL.

(3) Accuracy specification for calibrated spans from 1:1 to 6:1 of URL only.

4

Product Data Sheet Calculatfon PM-1209 Revision O 00813-0100-4360, Rev JB Attachment C Page C5 of C28 March 2010 Rosemount 1151 Outputs Code S, Smart 4-20 mA de, user seleclable for Ifnear or square root output Digital process variable superimposed on 4-20 mA sfgnal, available to any host that conforms to the HART protocol.

Code E, Analog 4-20 mA de, linear with process pressure Code G. Analog 10-50 mA de, linear with process pressure Code L, Low Power 0.8 to .3.2 V de, linear with process pressure Code M, Low Power 1 to 5 V de, linear with process pressure TABLE 3. Output Code Availability Code 1151 Output OptionsfDampmg DP HP GP DP/GP/Seals AP LT S 4-20 mA, Digital, SmarWariable E 4-20 mA, Linear, AnalogNariable

G(1) 10-50 mA. Linear, Analog/Variable

t to o.B 3.2 v, Linear, Low Power/Fixed NA (1)

M to v, 1 5 Linear, Low Power/Fixed Nat avsna/J/9 with CE mark.

NA Current Consumption Under Normal Operating Power Supply Conditions (Low Power Only) External power supply required. Transmitter operates according to Output Code l the following requirements:

1.5 "!l~dc Output Codes S, E Output Ccide M 12 to 45 V de with no load 2.0mAdc Output Code G 30 to 85 V de with no load Zero Elevation and Suppression Output Code L Output Codes S, E, and G 5to 12V de Zero elevation and suppression must be such that the lower Output Code M range value Is greater than or equal to the (-URL) and the Sto 14Vdc upper range value ls less than or equal to the (+URL). The calibrated span must be greater than or equal to the minimum Where:

span and less than or equal to the maximum span.

Output Code L Zero Is adjustable +/-10% of URL and span is adjustable from 90 to 100% of URL output Code M Operating Zero Is adjustable :t50% of URL and span is adjustable from Region 50 to 100% of URL Rmtn =-----~----___.

0 Vmln Vs Vmax Span and Zero Output Code S Span and zero may be accessed with local adjustments or remotely through a HART-compatible Interface.

'I*

s eC2)

min Vmax 12 12 45 45 Rmm 0

0 Rma 1650 1650

+h"Pd'Fi.LIM RL = 43.5 (Vs -12)

=

.RL 50 (Vs-12)

Output Codes E, G. L, and M Span and zero are continuously adjustable.

G 30 85 0 1100 =

RL 20 (Vs - 30)

L 5 12 Low Power Minimum Load M 8 14 Impedance: 100 kfi (1} A minimum of 250 ohms Is required for communication.

(2} For CSA approvals Vmalt= 42.4 V de.

5

Calculation PM-1209 Revision 0 Product Data Sheet Attachment C 00813*0100-4360, Rev JB Page C6 of C28 Rosemount 1151 March 2010 Static Pressure Limits Burst Pressure All Models Transmitters operate within specifications between the followlng 10,000 psig (68.95 MPa) proof pressure on the flanges.

limits:

Humidity Limits Rosemount 1151 DP Oto 100% relative humidity 0.5 psis to 2.000 pslg (3.45 kPa to 13790 kPa).

Rosemount 1151HP Volumetric Displacement 0.5 psia to 4,500 pslg (3.45 kPa to 31027 kPa). Less than 0. 01 in3 (0.16 cm 3)

Rosemount 11S1AP Failure Mode Alarm (Output Code S)

Opsla to the URL. If self-diagnosis detects a gross transmitter failure, the analog signal will be driven below 3.9 mA or above 21 mA to alert the Rosemount 1151GP user. High or low alarm signal Is user selectable.

0.5 psla (3.45 kPa} to the URL.

Overpressure Saturation Value (Output Code S)

Rosemount 1151LT If the sensor detects a negative overpressure value, the analog Limit Is 0.5 psla (3.45 kPa) to the flange rating or sensor rating, signal will be driven to 3.9 mA. If the sensor detects a positive whichever Is lower. overpressure value, the analog signal Is driven to 20.8 mA.

Overpressure Limits Level 4-20 mA Saturation Value 4-20 mA Alarm Value Transmitters withstand the following limits without damage: Low 3.9mA 3.SmA

High 20.BmA 21 .75 mA Rosemount 1151DP 0 psla to 2,000 psig (0 to 13790 kPa). Transmitter Security (Output Code S)

Rosemount 1151HP Activating the transmitter security function prevents changes to the o psla to 4,500 pslg (Oto 31027 kPa). transmitter configuration, Including local zero and span adjustments. Security is activated by an Internal switch.

Rosemount 1151AP o psla to 2,000 psla (0 to 13790 kPa). Damping Numbers given are for silicone fill fluid at room temperature. The Rosemount 1151GP minimum time constant is 0.2 seconds (0.4 seconds for Range 3).

Ranges 3-8: 0 psia to 2,000 psig (0 to 13790 kPa). Inert-filled sensor values would be slightly higher.

Range 9: O psla to 4,500 pslg (31027 kPa). Output Code S Range 0: 0 psla to 7,500 psig (51710 kPa). Tlme constant Is adjustable in 0.1 second Increments from minimum to 16.0 seconds.

Rosemount 1151LT Output Codes E and G Limit is 0 psia to the flange rating or sensor rating, whichever is lower. See Table 4. Time constant contlnuously adjustable between minimum and 1.67 seconds.

TABLE 4. Flange Pressure Rating output Codes L, M Carbon Steel SST Damping Is fixed at minimum time constant.

Standard Class Rating Rating 1151LT ANSI 150 285 pslg 275 pslg Time constant contfnuously adjustable between 0.4 and 2.2 ANSI . 300 740*J'.>stg<1> 720 psig<1} seconds with silicone oil fill, or 1.1 and 2.7 seconds with inert fill for flush models and eleclronlcs codes E or G ANSI 600. . 1,480 psig<1> 1.440 pslg<1>

DIN .PN 1°0-40 40 bar<2> 40 bar<2> ..

Tum-on Time DIN PN 10/16 .. 16 bar<2> . '16 barC2>

Maximum of 2.0 seconds with minimum damping. Low power DIN . . PN.25/40 . 40.bar<2> 40 bar<2> output is within 0.2% of steady state value within 200 ms after (1} At 100 °F (38 °C}, the rating decreases with Increasing application of power.

temperature.

(2) At 248 °F (120 °C), the rating decreases with lncraaslng temperature.

6

Product Data Sheet Calculation PM-1209 Revlslon o 00813-0100-4360, Rev JB Attachment C Page C7 of C28 March 2010 Rosemount 1151 Temperature Limits Operating Code S:-40 to 185 °F (-40 to 85 °C)

Code E: -40 to 200 °F (-40 to 93 °C)

Code G, L. M: -20 to 200 °F (-29 to 93 °C)

Storage Code S: -SO to 185 °F (-51 to 85 °C)

Codes E, G, L, M:-60 to 250 °F (-51 to 121 °C)

Process At atmospheric pressures and above.

TABLE 5. Rosemount 1151 Temperature Limits.

Rosemount 1151DP, HP, AP, GP, LT Sillcone Fill Sensor -40 to 220 °F (-40 to 104 °C)

Inert Fill Sensor 0-to 160 Of (-18 to 71 °C)

Rosemount 1151LT High-Side Temperature Limits (Process Fill Fluid)

)

Syltherm XLT -100 to 300 F (-73 to 149 C) o.c. Slllcone 104 60 to 400 °F (15 to 205 °C) .. -

D.C. Slllcone 200 ~40 to 400 Of (-:40 to 205 °Cj Inert n

-50 to 350 °F (-45 to 1 °C)

Glycerin and water{1) to 0 200 °F {"".'18 to 93 °C)

Neobee M-20<2>

0 to 400 °F (-18 to 205 °C)

Propylene Glycol an.Cl *water<~> 0to 200 °F {-18 t~. 93 °C)

Syltherm 800 -50 to 400 °F (-45 to 205 °C)

(1) Not suitable for vacuum service.

(2) Not compatible with Buna..N or Ethylene-Propylene 0-ring material.

TABLE 6. Fut Fluid Specifications Coeff. of Therm. Exp. Viscosity at 25 °C Fill Fluid Temperature Limits(1l Specific Gravity cc/ccl"F (cc/cc/"C) centistokes D. C. '*' 200 Slllcone -40 to 400 F (-40 to 206 C) 0.934 0.00060 (0.00108) 9.5

D. C~ 704 Silicone 60 to 400 °F (15 to 204 °C) 1.07 0.00063 (0.00095) 44 Inert Fill -SO to 350 °i='c-45 to 177 °C) 1.85 *0.0004 co.oooes4) 6.5

. SylthermXL7; Siiicone -100 to 300 °F (-73to149 °C) 0.85 0.000666 (0.001199} 1.6 Glycerin and Water<2)

0 to 200 °F (-17 to 93 °C} 1.13 0.00019 (0.00034) 12.5 Propylene Glycol and Water<3> 0 to 200 °F (-17 to 93 °C) 1.02 0:00019 (0.00034) 2.85 Neobee M~20<3 >

0 to 400 °F (-17 to 205.0 c) . 0.900 0.00056 (0.001008) 9.8 (1) Temperature nmJts are reduced In vaauum service. Contact an Emerson Process Management representative for assistance.

(2) Glycerin and Water and Propylene Glycol and Water are not suitable for vacuum seNlce.

(3) Not compatible with Buna..N or Ethylene-Propylene 0-ring material.

7

Calculation PM-1209 Revision O Product Data Sheet Attachment C 00813-0100-4360, Rev JB Page CS of C28 Rosemount 1151 March 2010 Physical Specifications, Reference Flange and Adapter CF-BM (Cast version of 316 SST, material per ASTM-A743).

Standard Configuration Non-wetted Materials Electrical Connections 1/2:-14 NPT conduit with screw terminals and Integral testjacks Fill Fluid compatible with miniature banana plugs (Pomona 2944, 3690, or Silicone off or inert fill

~qulvalen~). The HART Hand-Held Interface connections are fixed Nuts and Bolts to the terminal block on smart transmitters. Plated carbon steel Blank flange (GP and AP only)

Wetted Materials Plated carbon steel Isolating Diaphragms Electronics Housing 316L SST, Alloy C-276, or Tantalum. See ordering table for Low-copper aluminum or CF-SM (cast version of 316 SST) availability per model type. NEMA4X DralnNent Valves Cover O*rlngs 316 SST or Alloy C-276, see ordering table for availability per Buna-N model type.

Paint Process Flanges and Adapters Polyurethane Plated carbon steel, 316 SST or CW-12MW (Cast version Alloy C-276, material per ASTM-A494), see ordering table for Process Connections availability per model type.

Wetted 0-rings Rosemount1151PP, HP, GP, AP Viton (other materials also avanable) 114-18 NPT on 2.125-ln. (54-mm) centers on flanges for Ranges 3, 4, and 5.

1151 LT Process Wetted Parts 1/4-18 NPT on 2.188-ln. (56-mm) centers on flanges for Flanged Procass Connection Ranges 6 and 7.

114-18 NPT on 2.250-ln. (57-mm) centers on flanges for (Transm/tt9r High Side)

Range 8.

Process diaphragms, Including process gasket surface 112:-14 NPT on adapters.

316L SST, Alloy C-276. or Tantalum. For Ranges 3, 4, and 5, flange adapters can be rotated to give centers of 2.0 in. (51mm),2.125 in. (54 mm), or 2.250 in. {57 Extension mm).

CF-3M (cast version to 316L SST, material per ASTM-A743) or CW-12MW (Cast version of Alloy C-276, material per Rosemount 1151LT ASTM-A494); fits schedule 40 and 80 pipe. High pressure side: 2-, 3-. or 4-ln., Class 150, 300 or 600 flange; 50, 80, or 100 mm, PN 40or10/16 flange.

Mounting Flange Low pressure side: 1/4-18 NPT on flange. 1/2-14 NPT on carbon steel or SST.

adapter.

Reference Process Connection (Transmitter Low Side) Weight 12 lb (5.4 kg) for AP, DP, GP, and HP transmitters, excluding Isolating Diaptwagms options. Meter option: Add 2 lb (1 kg) 316L SST. Alloy C-276, or tantalum.

TABLE 7. 1151LT Welght with Flange Flush 2-in (50mm) Ext 4*in. (100mm) Ext. 6-in. (150mm) Ext.

Flange! 1l lb (kg) lh . (kg) lb . {kg) lb. {kg)

. 2-ln., Class 150 18 (8.2): N/A NIA NIA

3-rn., c1ass 150 23 (10.4) 25 -(11.3) 26(11.8) 27 (12.3)

. 4-in., Class 150 29 (13.2) . 32 (14.5)- 34 (15.4) 36 (16.3) 2-ln., Class 300 20(9.1) N/A NIA NIA

.-3-fn.~ Cl~ss* 300 28 (12.7) . 30 (13.6) *31 (14.1) 32.(14.5) 4-ln., Class 300 38(17.2) 41 (18.6) 43 (19.5) 45 (20.4)

. 2~1n., ~la~s 600 2200:0) NIA .NIA -. NIA 3-in., Class 600 31 (14.1) 33 (15.0) 34 (15.4) 35 (15.9)

. ON 50. PN1~-40 2~ (~.1) N/A NIA NIA DN 80. PN 25/40 25(11.3) 27 (12.3} 28 (12.7) 29 {13.2)

DN.100, PN 10/16 25 (11_._3) 28 (12.7) . 30 (13'.6} 32 (14.5} .

ON 100, PN 25/40 29 (13.2) 32 (14.5} 34 (15.4) 36 (16.3)

(1) Stainless steel flange weights are fisted.

8

Product Data Sheet Calculation PM-1209 Revision O 00813-0100-4360, Rev JB Attachment C Page C9 of C28 March 2010 Rosemount 1151 Product Certifications Approved Manufacturing Locations Factory Mutual (FM) Approvals FM Explosion-Proof tag Is standard. Appropriate tag wlll be

Rosemount Inc. - Chanhassen. Minnesota, USA substituted if optional certification is selected.

Emerson Process Management GmbH & Co. - Wessling, Explosion-Proof: Class J, Division 1, Groups B, c. and D.

Germany Dust-Ignition Proof: Class II, Division 11 Groups E. F, and G; Emerson Process Management Asia Pacific Class 111, Division 1. Indoor and outdoor use. NEMA 4X.

Private Limited - Singapore Factory Sealed.

Beijing Rosemount Far East Instrument Co., Limited - Beijing, 15 Intrinsically safe for Class I, II, and Ill Division 1, Groups A, China B, C, D, E, F. and G hazardous locations In accordance with entity requirements and Control drawing 01151-0214 and European Directive Information 00268*0031. Non- incendive for Class I, Division 2, Groups The EC declaration of confonnlty for all appllcable European A. B, C and D hazardous locations.

directives for this product can be found on the Rosemount website For entity parameters see control drawing 01151-0214.

at www.rosemountcom. A hard copy may be obtained by contacting our local sales office. Canadian Standards Association (CSA) Approvals E6 Explosion-Proof for Class I, Division 1, Groups C and O; ATEX Directive (9419/EC) Class II. Division 1, Groups E, F, and G: Class Ill, Division 1 Emerson Process Management complies with the ATEX Hazardous Locations. Suitable for Class I, Division 2, Groups Directive. A. B, C, and D; CSA enclosure type 4X. Factory Sealed.

16 Intrinsically safe for Class I, Division 1, Groups A, B, c, and European Pressure Equipment Directive (PED) (97123/EC) D hazardous locations when connected per Drawing 1151GP9, O; 1151HP4, 5, 6, 7, 8 Pressure Transmitters 01151-2575. For entity parameters see control drawing

- QS Certificate of Assessment - EC No. PED*H-100 01151-2575. Temperature Code T2D.

Module H Conformity Assessment All other 1151 Pressure Transmitters Measurement Canada Approvals

- Sound Engineering Practice C5 Accuracy Approval to the Electricity and Gas Inspection Act Transmitter Attachments: Diaphragm Seal - Process Flange - for the purchase and sale of natural gas.

Manifold

- Sound Engineering Practice European Certifications Electro Magnetic Compatibility (EMC) (20041108/EC) 11 ATEX Intrinsically Safe and CombusUble Dust

'All models (1151 Smartonly)

-EN 61326: 1997 with Amendments A1. A2, and A3 Certificate No.: BAS99ATEX1294X ATEX Marking @ 11 1 GD EEx ia llC TS (-60°C s Ta :s: 40°C)

EEx la llC T4 (-60°C :s: Ta :s: 80°C)

Hazardous Locations Certifications CE 1180 IP66 North American Certifications TABLE 8. IS Entity Parameters Ordinary Location Certification for Factory Mutual Ui =30V As standard, the transmitter has been examined and tested 11=125 mA to determine that the design meets basic electrlcal, Pl= 1.0 W (T4) or 0.67 W (TS) mechanical, and fire protection requirements by FM, a Cl =0.034µF nationally recognized testing laboratory {NRTL) as LI= 20 ~H accredited by the Federal Occupational Safety and Health Special Conditions for Safe Use (X)

Administration (OSHA).

The apparatus, is not capable of withstanding the SOOV test as required by EN 50020: 1994. This must be taken into account when lnstalllng the apparatus.

9

Calculation PM-1209 Revision O Product Data Sheet Attachment c 00813~01004360, Rev JB Page C10 of C28 Rosemount 1151 March 2010 N1 ATEX Type n and Combustible Dust 17 SAA lntrlnslcaUy Safe (1151 Smart only) (1151 Smartonty)

Certificate No.: BAS 99ATEX3293X Certificate Number: Ex 122X ATEX marking: @ II 3 GO =

Ex la llC T5 (Tamb 40 °C)

EEx nL llC T5 (*40°C s Ta s 40°C) =

Ex Ia llC T4 (Tamb 60 °C)

EEx nL IIC T4 (-40°C s Ta ~ 80°C) Special Conditions for Safe Use (x):

=

Dust RaUng: T90 °c (Ta *20°C to 40°C) The equipment has been assessed to the entity concept and

=

U1 45 Vdc Max accordingly the following electrical parameters .mustbe

(( taken into account during installation.

IP66 Special Conditions for Safe Use (x) TABLE 9. Entity Parameters The apparatus ts not capable of withstanding the SOOV u1=aov Insulation test required by EN 50021: 1999. This must be 11=125mA taken Into account when Installing the apparatus. =

P1 1.0 W (T4} or 0.67W (T5)

C1 =14.8nF EB ATEX Flame-Proof 4=20 .~

Certification Number CESI03ATEX037 N7 SAA Type n ATEX Marking @ II 1/2 G {1151 Smart only)

EEx d !IC TS (-40 s Ta s 40 °C) Certificate Number: Ex 122X EExd llC T4 (-40s Ta~ 80 °C) Ex n llC T6 (Tamb =40 °C)

C 1180 Ex n llC T5 (Tamb = 80 °C}

V = 60 Vdc maximum IP66 Special Conditions for safe use (x):

Australian Certifications The equipment must be connected to a supply voltage which does not exceed the rated voltage. The enclosure end Standards Association of Australia (SAA) Certification caps must be correcUy fitted whilst the equipment is E7 SAA Flame-proof energized.

Certificate Number Ex 494X Exd llB +H2 T6 Combination Certifications DIPT6 Stainless steel certification tag Is provided when optional approval IP65 is specified. Once a device labeled with multiple approval types ls Special Conditions for safe use (x): Installed, it should not be reinstalled using any other approval For transmitters having NPT, PG or G cable entry threads, types. PermanenUy mark the approval label to distinguish It from an appropriate flame-proof thread adaptor shall be used to unused approval types.

facllltate application of certified flame-proof cable glands or C6 Comblnatlon of 16 and ES, conduit system. K5 Combination of FM Approvals Explosion-Proof and 15.

K6 Combination of E6, 16, 11, and ES 10

Product Data Sheet Calculatfon PM-1209 Revision O 00813-0100-4360 1 Rev JB Attachment C March 2010 Page 011 of 028 Rosemount 1151 Dimensional Drawings 1151 Transmitter 7.5 (191) Max.

Yr-14NPT with Optional Meter Conduit Connection 4.5 (114)

{2 Places)

Max.

Meter.

Housing

%-18NPTon Flanges for Pressure Connection without Ff ange Adapters 4 ,5 (114)

Max. x Permanent Tag (OptlonaQ i

9.0 (229)

Max.

Nameplate Y-18NPTfor Side DrainNent (Optional Top or Bottom) 3. 9 (94)

Flange Distance "A" Center to Center

'\.,

Range inches mm

.,Flanges Can 3,4,5 2.125 54 Be Rotated 6, 7 2.188 56 Flange 8 2.250 57 Adapter 4.5 9 2.281 58 (114) 0 2.328 59 NOTE Dimensions are In Inches (mllllmetars).

11

Calculation PM-1209 Revision O Product Data Sheet Attachment C 00813-0100-4360, Rev JB Page C12 of C28 Rosemount 1151 March 2010 Typica( Transmitter Exploded View with Smart Electronics Terminal Eyelets Transmitter Security and Failure Mode Alarm Switches Zero and Span Buttons 8-Cell l"' Sensing Module Blank Flange for AP and GP 12

Product Data Sheet Calculation PM-1209 Revision O 00813-0100-4360, Rev JB Attachment C Page C13 of C28 March 2010 Rosemount 1151 1151LT 11.::.89) rl _____

Serrated Face Gasket Surface Permanent Tag nt Valve (optlo al) __,._

1 .

I 4.5 (114)

Max.

I J._ _ .___;~-'-'

OPTIONAL FLUSHING l -

CONNECTION RING A 2-, 4-, or 6-in. (LOWER HOUSING) 4.45 (113) -*""4--~- (51, 102, or152) 1

- 1 Max. Extension (25)-r rr=

lL Flushing Tennrnal Connections Connection

~sing)

Meter r-\

________ , 1 This Side Nameplate (Remove for DIAPHRAGM ASSEMBLY Span and Zero Adjust) AND MOUNTING FLANGE I I I 7.5 (190.5)

Max. with OpUonal r-: ~

I I

c Me[jter114) ax. ,

%-14 NPT for %-1

- Conduit Connection on Flange %-18 NPT on (2 places) Adapters Flanges 0.75 (19) Clearance for Pressure for Cover Removal Connection (typical) without the Use of NOTE Flange Dimensions are In inches (millimeters).

13

Calculation PM-1209 Revision O Product Data Sheet Attachment C 00813-0100-4360, Rev JB Page C14of028 Rosemount 1151 March 2010 TABLE 10. 1151LT Dimensional Specifications 0 .0.

Flange Bolt Circle Outside Exten. Gask. Proc.

Pipe Thickness Diameter Diameter No. of Bolt Hole Diam. Surf. Side Class Size A B C Bolts Diameter D 11) E G ANSI 150 2 (51) 1.12 (28) 4.75 (121) 6.0 (152) 4 0.75 (19) NA 3.6(92) 2.12 (54) 3 (76) 1.31 (33) 6.0 (152) 7.5 (191) 4 0.75 (19) 2.58 (66) 5.0 (127) 3.5 (89) 4 (102) 1.31 (33) 7.5 (191) 9.0 (229) 8 0.75 (19) 3.5 (89) 6.2 (158) 4.5 (114)

... ANSl300 2{51) 1.25 (32) *5;0 :(~27) 6.5-°(:1*65) :a *0.75'(19)

NA 3.6(92) 2:12(64) 3 (76) 1.50 (38) 6.62 (168) 8.25 (210) 8 0.88 (22) 2.58 (66) 5.0 (127) 3.5(89) 4 (102) 1.62 (41) 7.88 (200) 10.0 (254) 8 0.8~ {22) 3.5 (89) 6.2 (15~) :~-5 (114)

ANSI 600 2 (51) 1.12 (28) 5.0 (127) 6.5 (165} 8 0.75 (19) NA 3.6(92) 2.12 (54) 3 (76) 1.37 (35) 6.62 (168) .. 6.62 (168) 8 0.88 (22) 2.58 (66) 5.0 (127) 3.5 (89)

DIN DN50 26mm 125mm 1ssn1m 4 18mm NA 4.0 (102) 2.5 (63)

PN10-40 DIN DN80 30mm 160mm 200mm 8 18mm 65mm 5.4 (138) 3.7 {94)

PN 25140 DN 100 30mm 190mm 235mm 8 22mm 89mm 6.2 (158) 4.5 (114)

DIN DN 100 26mm 180mm *22omm 8 18mm 89mm *a.i c158> 4.5 (114}

PN 10/16 (1) Tolerances ar9 0.040 (1.02), -0.020 (0.51).

Mounting Bracket Option Codes 81, 84, and 87 2.81 2.625 (71) (67) 1-- 5.625 (143) _ __

5.625 (143)

NOTE Dimensions are In inches (millimeters).

14

Product Data Sheet Calculation PM-1209 Revision O 00813-0100-4360, Rev JB Attachment C Page C15 of C28 March 2010 Rosemount 1151 Panel Mounting Bracket Option Codes 82 and 85 Mounting Holes 0.375 (10) Diameter 2.81 (71)

Typlcal 1.40 (46) 2.81 (71} Typical 1.40 (36) 2.625

--*--(67)

NOTE Dimensions are in inches Flat Mounting Bracket Option Codes 83, 86, and 89 NOTE Dimensions are In Inches (mllllmeters).

15

Calculation PM-1209 Revision 0 Product Data Sheet Attachment c 00813-0100-4360, Rev JB Page C16 of C28 Rosemount 1151 March 2010 Meter Options

---111114-o.....- 0.75 (19)

Clearance fer Cover Removal (Typical)

OPTION CODE M1 LINEAR SCALE 9.0 (229)

Max.

OPTION CODE M4 LINEAR SCALE NOTE Dimensions are In fnches Flange Insert 1151 Process Connections Standard DratnNent Replaced with Plu~

~ *~

A'ternate Side ~~

DralnNent~ ~ ..~

Top Position (Option Code 01)

Alternate Side DralnNent Bottom Positlon__;,;/11 Kynar {Option Code 02)

Insert '%-14 NPT Connection on Adapters (Optlon code DF) 16

Product Data Sheet Calculation PMM1209 Revision O 00813..CJ100M4360, Rev JB Attachment C Page 017 of C28 March 2010 Rosemount 1151 Ordering Information

=Applicable - =Not Appllcable Model Transmitter Type DP HP GP AP 1151 DP Differential Pressure Transmitter *

1151 HP Differential Pressure Transmitter*for High Line Pressures

1151GP Gage Pressure Transmitter * *

1151Ai2 A~sah~te Press~Fe traF161,iitter*** * ** * *** ... * * ** Discontinued Code Pressure Ranges (URL) (select one} DP HP GP AP 3 30 lnH20 (7.46 kPa) *

4 150 lnH20 (37.3 kPa) * * *

5 750 inH20 (186.4 kPa) * * *

6 100 psi (689.5 kPa) * * *

7 300 psi (2068 kPa) * * *

8 1,ooo psi (6895 kPaj * *

9 3,ooo psi (20684 kPaj

8 s.000 psi (41 ase 1tra) Discontinued Code Transmitter Output (select one) DP HP GP AP 4-20 mA with Digital Signal based on HART Protocol (Smart) * * *

4-20 mA, Linear with Input * * * * *

19 69 ffi,*\ blRear 'NitA IAf3l:lt Discontinued Low Power 0.8 to 3.2 Vdc * * *

Len Peoer 1 te 6 Vee Discontinued MATERIALS OF CONSTRUCTIONl 3 1 Code Flanges/Adapters DrainsNents Diaphragms Fill Fluid DP HP GP1 4 l AP'..i 1 52 Nlckel-plated Carbon Steel 316SST 316LSST Silicone * * *

53 Nickel-plated Carbon Steei 316SST AlloyC:27S Silicone * * *

55 * -Nickel-plated Carbon *steel 316SST Tantalum Sillcon*e *

22 316 SST . . 316SST 318L ssr* Silicone * * *

23 316SST 316ssr* Alioy C-276 . Slllcone * * *

25 316~SST 316SST Tantalum Silicone * ..

3a<5 > Cast C-276 AlloyC-276 Alloy C-276 Siiicone * * *

35 caste-216 AlloyC-276 Tantalum Sllicone *

73cs> 31e *ssT Alloy C-276 .AlloyC-276 Slllcone * * *

83<5> Nicker-Plated Carbon Steel . Alloy C-276 AlloyC-276 Slllcone * * *

5A 'Nickel-plated Carbon Steel 316SST 316LSST Inert *

5B Nickel-plated Carbon Steel 316SST AlloyC-276 Inert *

50 Nickel-plated Carbon Steel 316SST Tantalum Inert *

2A 316SST 316SST 316LSST Inert *

28 316SST 316SST AlloyC-276 Inert *

20 316 SST a1a sst Tantalum

Inert *

38 Cast C:276 AlloyC-276 AlloyC-276 Inert *

30 Cast C-276 AlloyC-276 Tantalum Inert *

79(5) 316 SST Alloy C-276 AlloyCM276 Inert *

ae<5> Nickel-pf ated Carbon Steel Alloy~276 AlloyC.276 Inert *

Code Mounting Brackets (optional - select one) DP HP GP AP B1 Bracket, 2-in. Pipe Mount * * *

B2 Bracket, Panel Mount * * *

83 Bracket, Flat, 2-Jn. Pipe Mount * * *

84 81 Bracket w/Series 316 SST Bolts. * * *

85 a2*Bracket w/Series 316 SST Bolts * * *

86 83 Br:acketw/Series 316 SST Bolts * * *

67 316 SST 81 Bracket with 316 SST Bolts * * *

99 316 SST B3 Bracket with 316 SST Bolts * * *

17

Calculation PM-1209 Revision O Product Data Sheet Attachment C 00813-0100-4360, Rev JB Page 018 of 028 Rosemount 1151 March 2010 Code LCD Drsplay<f*l (optional - select one) DP HP GP AP M1 Analog Scale, Linear Meter, 0-100% * *

M2 Analog Scale, Square Root Meter, 0-100% Flow *

M4<7>

..Ms LCD Display, Linear *Meter, 0..:100% * * * *

Anaiog"s"caie, Square Root Meter, 1-10/ * * . ..

M7(7)(S) Let>' Display, Linear Meter, Special Configuration * * *

M8(7)

Mg(7)

LCD Display Square Root Meter, 0-100% Flow *

LCD Display, Square Root Meter, 0-10/ . *

Code Product Certifications (optional - select one) OP HP GP AP ES ATEX Flameproof * *. *

11C9) ATEX 1nti-lns1c*safety NOTE * * *

N1<9> ATEXTypen FM explosion-proof approval Is standard. * * *

15<9> FM Intrinsically Safe, Division 2 * * *

K5<9> FM Explosion-Proof, Dust lgnftroniJroof, li:ttrinslcally Safe, Division 2 * * *

ca<9> CSA Explosion-Proof, Intrinsically Safe * * *

1a<9> CSA Intrinsically Safe * * *

K6<9> CSA Explosion-Proof. Dust Ignition-proof, Intrinsically Safe, Division 2 * *

E6 CSA Explosion-Proof, Dust Ignition-proof, Division 2 * * *

E7 1-,(9)

SAA Flameproof, Dust lgnltioniJroof * * *

SAA Intrinsic Safety * * * *

N7C9) SAA Typen * * *

csc10> . Measurement Canada Accuracy Approval * * *

H1 SST Non-wetted Parts on Transmitter without Meter H2(11) SST Non-wetted Parts on Transmitter With Meter * * *

H3 SST Housing. Cove~, Con~ult Plug, Lock-nut, *without Meter-. * * *

H4 SST Housing, Covers, Conduit Plug, Lock-nut, with Meter * * *

C2(12) M20 Conduit Threads * *... * *

j1 G~ Conduit Threads * * *

Code Terminal Blocks (optional - select one) DP HP GP AP R1 Integral Transient Protection (Only available with output options S and E) * * *

Code Bolts for Flanges and Adapters (optional - select one) DP HP GP AP L3 ASTM A193-87 Flange and Adapter Bolts * * *

L4 316 SST Ffange and Adapter Bolls * * *

LS *ASTM A193~B7M Flange and Adapter-Bolt& * * *

Code P(ocess Connections (optionaJl 13 l) Matenals DP HP GP AP 01 Side Drain/ Vent. Top 316 SST * * *

castc-276 * * *

D2 Side o*rarril Vent, Bottom 316SST * * *

CastC-276 * * *

OF Y2'""14 NPT Flange adapter(s)- Material determined*by flange inatenal Carbon Steel 316 SST

04(14)

CastC-276 * * * *

- Conformance to DIN EN61618 Ranges a,*4; 5with KNPT.Process Connections *

Thread (Available In G.er~any <?nly) cj5(14) Conformance to DIN EN61518 Ranges e, i, 8, wHt\out % NPT Process Connections *

Thread (Available in Germany Only) ..

. 06 316 SST Low Side Blank Flange *

09 JIS Process Connection_:RC % Flange with RC % Flange Adapter Carbon Steel * * *

316SST * * *

castC-276 **- * *..

G1 DfN. Spacing {Single Entry Port; No Side V/D.Hole Flange) * * * *

'32 DIN Spacing (Single Entry Port, Two Side V/D Hole Flange) * * *

G3 DIN Spacing {Dual Entry Port, No Side V/D Hole Fla.nge) ** * * * *.

G4 DIN Spacing (Dual Entry Port, One Top Side V/D Hole Flange) * * *

G5 DIN . ~cirig (Dual. ~ntry Port, One Bottom Side Y_ID Hole Flange) * * *

G6 DIN Spacing (Dual Entry Port, Two Side V/D Hole Flange) * * *

18

Product Data Sheet Calculation PM-1209 Revision 0 00813..0100-4360, Rev JB Attachment C Page C19 of C28 March 2010 Rosemount 1151 K1(15)

K2(15)

Kynar Insert, %-18 NPT *

Kyriar Insert, Yz--14 NPT *

51(16)(17) Assemble to one RosemoLirit 1199 diaphragm seal *

s2'1s>c11> Assemble to tWo Rosemount 1199 diaphragm seals *

. 54(11x1s) Assemble to Rosemourit 1195 Integral Orifice *

ss<11r Assemble to Roseniount.304 Manifold or connection* system * * * *

Code Wetted 0-ring Material (optional - select one) DP HP GP AP W2

wa

.. W4 Buna-N

-~-~Y!~_ne-Pr~~Y}~~e ws<19>c20>

Aflas * * *

Spring-loaded PTFE *

w7c2o>c21> PTFE * *

Analog Output Levels Compliant wlth NAMUR Recommendation NE43: 27-June-1996 and Low Alarm Level Analog Output Levels Compliant With NAMUR Recommendation NE43: 27-Jun&1996 and High Alarm * * *

Level c9c2a> Software Configuration (Requires compieted Configuration Data Sheet) * * *

Code Special Certifications (optional - select one) DP HP GP AP Q4 Callbration Certificate ..* * *

08c24> Material Traceability per EN 10204 3.1.B * * *

a1sC25 > Surface Finish certification for Sanitary Remote Seals * * *

_H~dr.ostatlc Testtng, _150% Maximum Work~ng Pressure Cleaning for Special Service * * *

Cleaning for <1 PPM Chlorine/Fluorine * * *

Reverse output 4-29 mV Test Signal * * *

20-'100 niv Test Slgnal * * *

Typccal Model Number: 11510P 4 S 52 83 M4 (1) Output Code G Is not avalleble with CE Mark.

(2} Meter or SST housing not valid with this option.

(3) Bolts and conduit plugs are plated carbon steel.

(4) On GP and AP transmitters, the /ow-side flange Is plated carbon steel. For a stainless-steel low-side flange, order process connection Option Code D6.

(5) These selections meet NACE material recommendations per MR 01-76.

(6) Not available with Output Codes L or M, or Option Codes V2 or V3.

(7) Not available with Output Codes Q VZ or V3.

(8) Specify the range, mode. and engineering units. The 20 mA value must be greater than the 4 mA value.

(9) Not available with Output Codes E, ~ L, or M.

(10) Umlted availabflity depending on transmitter type and range. Contact an Emerson Process Management representative.

(11) Option Includes SST housing, covers, conduit plug, locknut, L4 bolting, end D6 low side blank flange for GP and AP transmitters.

Option Codes L4 and D6 parts are Included with housing Option Codes H1 and H2.

(12) Not available with Output Codes L or M. Ava/fable only with aluminum housing.

(13} Al/owable combinations are: D1, 02, D6 or DB, S1.

(14) Material Traceability Certificate Option Q8 available.

(15} The maximum working pressure on this option Is 300 pslg. Available only with materials of construction Option Code 2x.

(16) This option may only be used an Ranges 4-8.

(17) Assemble-to" Items are specified separately and require a completed model number.

(18) This option has a maximum static pressure rating of 3,000 psi, and Is avallab/e only for Ranges 3, 4, and 5.

(19) Contains a Alloy C-276 spring that Is wetted by the process.

(20) Available for the ranges of DP (3-8). AP (4-8}, and GP (3-8).

{21) PTFE 0-rlng has seal property /Imitations; Consult an Emerson Proc9" Management representaUve for more Information.

(22) NAMUR-compliant operation Is pre-set st the factory and cannot be changed to standard operauon In the field.

(23) Available with Output Code Sonly.

(24) This option Is available for the transmitter flange and adapters only.

(25) Requires one of the Diaphragm Seal Assembly codes (S1 or S2}.

(26} Hydrostatic testing for Range 0, 125% maximum working pressure.

(27} F/uorolube grease on wetted 0-rlngs.

(28) Available with Output Codes E, ~ L, M; SST diaphragms; Spans of 10 lnH20 and greater.

(29} Reverse output option Is not needed with smart electronics; configured via HART-based communicator.

(30) Not avaflab/e with Output Codes L or M.

19

Calculation PM-1209 Revision 0 Product Data Sheet Attachment C 00813-0100-4360, Rev JB Page C20 of 028 Rosemount 1151 March 2010 Model Product Description 1151LT Flange-Mounted Liquid Level Transmitter Code Range 4 150 lnH20 (0-635 to 0-3,810 mmH20) 5 750 lnH20{0-3,175 to 0-19,050 mmH20) 6 2,7701nH20 (0-11.96 to 0-70.36 mmH20)

Code Output s 4-20 mA with Digital Signal based on HART Protocdl (Smart)

E 4-20 mA, Linear with Input * *

o'1>. 1.e-se '*' *'~*- ~1~a1Jrith lol:'at. Dlsqontlnued Code Size Material Extension Lengtt1 GO 2 in./DN 50 316L SST Flush Mount Only When specifylng*theseoption codes; a lower HO 2 lnJDN so Altoy e-21s Flush Mount Only housing must be selected from the flushing JO 2 Jn./DN 50 Tantalum Flush Mount Only connection options.

AO 3 lnJON 80 316LSST Flush Mount

A2 3 in./DN BO 316LSST 2 ln./50 mm A4 3 tn./DN 80 316LSST 4ln./100 mm A6 3fn./D.N 80 316LSST 6 lnJ150 mm BO 4in.ION100 316L SST Flush Mount NOTE 92 41n./DN 100 316LSST 21n.150 mm Extension diameters are sized to fit Schedule 80 pipe. Consult factory for Schedule 40 pipe.

84 41n./DN 100 316L SST 4in./1oci mm 86 4in:!DN100 316LSST 6 !nJ150mm co 31n./DN 80 AlloyC-276 Flush Mount C2 3 in.ION 80 Alloy C-276 21nJ50mm C4 3 ln./DN 80 Allo}i C-276. 4 ln.1100 mm C6 3 inJDN 80 AlloyC-276 6inJ150mm DO 4in.ION100 * *Alfoy c~21a Flush Mount 02 4 lnJDN 100 AlloyC-276 2 ln./50 mm 04 4 tn./DN 100 Alloy C-276 41n./100 mm 06 4in.ION100 Alloy C:.276 61nJ150mm EO 3inJDN80 Tantalum Flush Mount Only FO 4ln./DN100 Tantalum Flush Mount only MOUNTING FLANGE Applicable with these Higl1 Pressure Side Code Size Rating Material Diaphragm Sizes M 2-in. Class 150 cs 2inJON50 A 3-ln. Class f50 cs 3 ln.iD'N 80 B 4-in. Class 1so cs 4tnJDN.100 N 2-in. Class 300 cs .. 2 in:tDN 50 c 3-in. Class 300 cs 3 InJDN 80 D 4-in. Class 300 cs 4inJON 100 p 2-1n. ciasseoo *cs 2 ln./ON 50 E 3-ln. Class600.

cs 3 ln:/ON ao x 2-in. Class 160 SST 2 in.ION SO F 3-!n. Class fso* SST 3 inJDN 80 G 4-in. .. Class 1so SST 4 In.ION 100 y 2-1n. Class 300 SST 2 lnJbN 50 H 3-ln. Class 300 SST 31n.iDN80 J

4-in. C!ass300 SST .

4in.ION100 z 2-in. c1ass600 SST 2.tnJDN 50 L 3-tn. Class 600 SST 3 ln./DN 80 Q DN50 PN 10.40 cs 21nJDN 50 R DN80 PN40 cs ... 31nJDN 80 s DN100 PN40 cs 4 in.ION 1oo*

v DN 100 PN 10/16 cs** 41nJON 100 k DN50 PN 10-40 SST 2 rnJDN so T DNBO

PN40 SST 31nJDN80 u DN 100 PN40 SST 41nJDN 100 w ON 100 PN 10/16 SST 4tn./DN 100 20

Product Data Sheet Calculatron PM-1209 Revision 0 00813-0100-4360, Rev JB Attachment C Page C21 of C28 March 2010 Rosemount 1151 SENSOR MODULE AND LOW-SIDE MATERIALS OF CONSTRUCTION Low-Side Flange Low-Sido Isolator Code and Adapter Drain/ Vent Valves Diaphragm Low-Side Fluid Fill 52 Nickel-plated CS 316SST 316LSST Silicone 55 Nlckel-plated CS 316SST Tantalum Siiicone 22 316 SST . 316SST 316L SST Siiicone 23 316SST 316SST AlloyC-276 *smcone 25 316SST 316SST Tantalum Slllcone 33 CastC-276 Alloy C-276 Alloy C-276 Silicone 35 Cast°C-276 AlloyC-276 ..

Tantalum Slllcone 50 Nickel-plated cs 316SST Tantalum Inert 2A 316 SST 316SST 316LSST Inert-2B 316SST 316-SST AlloyC-276 Inert 20 316 sST 316 SST Tantalum Inert 3B castd-276 Alloyc~2*1a

Alloy c.:216 *

Inert 30 CastC-276. Alloy C-276 Tantalum Inert Code Process Fill - High Pressure Side Temperature Limits A Sylthenn XLT -100 to 300 °F (-73 to 135 °C) c D. C. Siiicone 704 60 lo 400 Of (15 to 205 °C)

D D. C. Silicone 200 -40 to 400 °F (-40 to 205 °C)

H Inert -50 to aso *f: (-45 to.177 °b)

G Glycerin and Water ri to .200 °F (-17 to 93 *c)

N Neobee M-20

6 to 400 *j: (-17 to 2o5*°C) p Propylene Glycol and Water 0 to 200 °F (-17 to 93 °C)

Assemble to one Rosemount 1199 diaphragm seal LCD 0*1splay - - ..

M1C4> Analog Scale, Linear Meter 0-1.00%

. M4C4 >> LCD Display, 0-100%

rv17C4X5) LCD Dlsplay, Llnear, Special Configuration HAZARDOUS LOCATIONS CERTIFICATIONS ES ATEX Flameproof 11<6> ATEX Intrinsic Safety NOTE FM explosion-proof approval Is standard.

N1C6> ATEXType*n 1s<6> F.M Intrinsically Safe, Division 2 K5<6> FM Explosion-Proof, Dust Ignition-proof~ Intrinsically Safe, Division 2 ca<6>

CSA Explosion-Proof, Intrinsically Safe 1e<6> CSA Intrinsically Safe K6<6 > CSA Explosion-Proof, Dust Ignition-proof, Intrinsically Safe, Division 2 E6 CSA Exploslon--Proof, Dust Ignition-proof, Division 2 E7 SM Flameproof, Dust Ignition-proof 17<6) SAA Intrinsic Safety N7(6) SAA Typen cs< 7> Measurement *c*anada Accuracy Approval 21

Calculation PM*1209 Revision O Product Data Sheet Attachment C 00813-0100-4360, Rev JB Page C22 of C28 Rosemount 1151 March 2010 OTHER OPTIONS W5 Copper 0-ring for Vacuum Service (Nonwetted) c2<8> M20 Conduit Thread*s *

Q4 Calibration Data Sheet a*a<9> Material Traceability per EN 10204 3.18 Q16 Surface Finish Certification for Sanitary Remote Seals (all opUons)

Qz Remote Seal System Performance Calculation Report v1C 10> Reverse Output

'\/2 4-20 mV Test Signal V3 oo 20-1 mv Test Signal F_ Select On~ Code from Ffushlng Connections Lower Housing Option. SeeTable 11.

Typical Model Number: 1151LT 4 S AO A 52 D F1 (1) Not ava/fable with Output Codes E and G (2) For welded caplllary assemblles, order sensor modu/9 and /ow-side materials of constrvcffon Option Code 22 (refer to 00813-0100-4018 for more Information).

(3) uAssembfe-to" Items are specified separately and require a completed model number.

(4) Not available with Option Codes V2, or V3.

(5) Specify the Range, Mode, and Engineering Units. Also, the 20 mA value must be greater than the 4 mA value.

(6) Not available with Output Codas E and G (7) Limited availability depending on transmitter type and range. Contact an Emerson Process Management representative.

(8) Not available with Output Codes L or M. Aval/able only with aluminum housing.

(9) Avallable for the diaphragm, upper housing, flange, adapter, extension, and lower housing.

(10) Reverse output option Is not needed with smart electronics; configured via HART-based communicator.

TABLE 11. Flushing Connections Lower Housing Options

=Applicable - ::: Not Applicable Flushing Connection Ring Flushing Diaphragm Size Code Material (lower Housmg) Connections Size 2-m. 3-in. 4-m.

F1 SST 1 /4-18 NPT *

SST 2

1/4- .18 NPT F2 * *

F3{1) 114-18 NPT castc-21a * *

F4<1> . Cast C-276 2 1/4-1S NPT * *

1/2-14 NPT F7 SST 1 *

1/2- *14 NPT F8 SST 2 * *

f9 FO .

CastC-276 CastC-276 2 1 12~ 14 NPT 1/2-14NPT (1) Not available with high pressure side Option Codes AO, BO, and GO.

22

Product Data Sheet Calculation PM-1209 Revision O 00813~0100-4360, Rev JB Attachment C Page C23 of C28 March 2010 Rosemount 1151 Standard Accessories Bolts and Nuts for Flanges and Adapters All models are shipped with drain/vent valves, and one Instruction Options permit bolts and nuts for flanges and adapters In the manual per shipment. specified material.

L3 ANSl/ASTM A ~ 193-87 Tagging

L4 Austenltic 316 SST The transmitter will be tagged, at no charge, in accordance with

L5 ANSl/ASTM A193-87M customer requirements. All. tags are stainless steel. The standard tag is wired to the transmitter, however a permanently attached tag Meters is available upon request Tag character height Is 0.1'25 in. (0.318 Analog

~~ .

Meters have 2-ln. (50.8 mm) scale

Plug-In mounting configuration Calibration

Indication accuracy +/-2%

Transmitters are factory calibrated to the customer's specified

Operating temperature limit: -40 to 150 °F (-40 to 65 °C) range. If calibration is not specified, the transmitters are calibrated

Meters are enclosed In a housing certified by Factory Mutual at maximum range. Calibration is performed at ambient as Explosion*Prooffor Class I, Division 1, Groups B, C, and D; temperature and pressure. Class II, Division 1, Groups E, F, and G and Class Ill, Division 1

Options

For opHonai CSA explosion-proof approval, see certification The following sections describe a variety of available options for Option Code E6 the 1151 Transmitter. These options permit greater application

M1 Linear Analog Meter, 0-100% Scale flexlblllty.

M2 Square Root Analog Meter, 0-100% Flow Scale

M6 Square Root Analog Meter, 0- 1O"" Scale Optional Manifolds LCD Refer to Manifold Product Data Sheet (document number

4-dfglt display 00813-0100-4839).

Indication accuracy +/-0.25% of calibrated span :1:1 digit

Display resolution at +/-0.5% of calibrated span +/-1 digit Optional 9,laphragm and Sanitary Seals

Operating temperature limit: -4 to 158 °F (-20 to 70 °C)

Refer to Pr~uct Data Sheet (document numbers

Plug-In mounting configuration 00813-010cko16 or 00813-0201-4016)

Meters are enclosed in a housing certified by FM as Explosion-Proof for Class I, Division 1, Groups B, C, and D; Mounting Brackets Class II, Division 1, Groups E, F, and G and Class Ill, Division 1 81 Bracket for 2-in. Pipe Mounting

For Optional CSA explosion-proof approval, sea certification

Bracket for mounting transmitter on 2-ln. pipe Option Code ES

Constructed of carbon steel with carbon steel U-bolt

Reverse output not available with LCD Display

Coated with polyurethane paint

M4 Linear LCD Meter, Oto 100%

84 Bracket for 2-ln. Pipe with 316 SST Bolts

M7 Special Scale LCD Meter

Same bracket as Option Code 81with316 SST bolts

Specify:

87 304 SST Brad(et and 316 SST Bolls for 2-ln. Pipe Mounting *Range (2 OmA value must be greater than 4 mA

Same bracket as Option Code 81 with all SST materials value)

Mode 82 Bracket for Panel Mounting

Eng ineerlng Units

Bracket for mounting transmitter on panel or wall

M8 Square Root LCD Display, 0 to 100%

Constructed of carbon steel with carbon steel bolts

M9 Square Root LCD Display, 0-10V Scale

Coated with polyurethane paint B5 Bracket for Panel with 316 SST Bolts NOTES

Same bracket as Option Code 82 Meter Options are not available with Output Codes L or M, or with 316 SST bolts Option Codes V2 orV3. Meter Options M4, M7, MB, and M9 are not avallable with Output Code G 83 Flat Bracket for 2-in. Pipe Mounting

Bracket for vertical mounting of transmitter on 2-in. pipe

Constructed of carbon steel with carbon steel U-bolt

Coated with polyurethane paint 86 Flat Bracket for 2-ln. Pipe with 316 SST Bolts

Same bracket as Option Code 83 with 316 SST bolts 89 304 SST Flat Bracket and 316 SST Bolts for 2-ln. Pipe Mounting

Same bracket as Option Code 83 with all 316 SST materials 23

Calculation PM..1209 Revision 0 Product Data Sheet Attachment C 00813-0100-4360, Rev JB Page C24 of C28 Rosemount 1151 March 2010 Process Connections Wetted 0-rings 01 Side DralnNent-Top

Standard: Viton

Drain/vent valve mounted In side of flange.

W2 BunaN

Top position used to vent gas buildup in liquid process

W3 Ethylene-Propylene applications with transmitter mounted vertically.

W4Aflas

Plug of same material as requested flange inserted in end of

W5 CopperO-ring forVc)OJum Service (Nonwetted -1151LT only) flange opposite adapter.

W6 Spring-Loaded PTFE D2 Side DralnNent-Bottom

Contains a Alloy C-276 spring that Is In contact with the

Drain/vent valve mounted In side of flange. process fluid. Consult factory If Alloy C-276 ts

Bottom position used to drain liquid bulldup In gas process unacceptable.

applications with transmitter mounted vertically. * *W7PTFE

Plug of same material as requested flange Inserted in end of flange opposite adapter. Procedures 06 316 SST Low Side Flange (1151GP and 1151AP Only) Standard Configuration OF 1/2-14 NPT flange adapters Unless otherwise specified, transmitter will be shipped as

Options provide 1/2-14 NPT process connection on flanges follows:

rather than 114--18 NPT Engineering Units: lnH20 4mA: 0 K1 1/+-18 NPT Kynar' Process Flange Insert 20mA: Upper Range Limit K2 1/2-14 NPT Kynar Process Flange Insert Output: Linear

Options provide Kynar plastic process ff ange insert that Software Tag: Blank prevents process from coming Jn contact with the metal of the flange. One process insert for the 1151GP and LT; two inserts Customer may specify the above items at no charge. Software for the 1151DP. tag (8 characters) Is left blank unless specified.

Process connections are from the side. C9 Custom Configuration (Option Code C9)

Available with carbon steel and stainless steel process flanges If Option Code C9 is ordered, the customer may specify the only. followlng data In addition to the standard configuration

Pressure Maximum: 200 psi at 200 °F with Kynar Impulse parameters.

piping; 300 psi at 200 °F with metal impulse piping. Descriptor: 16 characters Message: 32 characters S1 Assembled with One 1199 Remote Diaphragm Seal Date: Day, Month. Year 52 Assembled with Two 1199 Remote Diaphragm Seals Damping: Seconds

Options provide for the assembly of one or two remote Burst Mode: Select Output Choice diaphragm seals. Failure Mode: High or Low S4 Assembled with 1195 Integral Orifice Transmitter Security: Off or On

Designed for highly accurate, small-bore flow measurement of any clean gas, liquid, or vapor.

Reduce the costs associated with traditional orifice plate Installations.

Several configurations are available factory assembled to Rosemount differential pressure transmltters.< 1>

Wide orifice bore/flow range capablllty.

Wide choice of process connections, Including threaded, socket weld, and ANSI flanges.

Static pressure maximum llmlt Is 3,000 pslg.

Wetted materials are avallable that comply with NACE MR 01~75(90).

Avallable only with Ranges 2, 3, 4, and 5.

(1) Applicable only to orifice assemblies without piping.

24

Product Data Sheet Calculation PM-1209 Revision o 00813-0100-4360, Rev JB Attachment C Page C25 of C28 March 2010 Rosemount 1151 Outputs TABLE 12. Hydrostatic Test Pressure V1 Reverse Output Model Test Pressure

This option permits reversing of pressure input so that 1151DP 3,000 psi electrical output will increase as pressure Input decreases.

1151HP 6,750 psi

This option applies only to 1151GP and 1151LT. When this 1151AP 2,00~. psl option ls selected, the process flange, adapter, drain/vent

' 11'51GP valve, appropriate O-rings, and bolting are Installed on low Ranges~ 2,000 psi side of transmitter. Not available for Ranges 9 and o.

Range9 "4,soo**psr

Notavallable with 1151 AP. Reverse .output on 1151 OP .and RangeO 7,500 psi 11'51HP can *be obtained 'by connecting*high-pressure inputlo 1151LT . low side of transmitter and vice versa.

Class 150 Flange 450 psi

This option should not be ordered with smart transmitters Cl~ss ~00.,.Flange _1,106 psi (Output Code S). The 1151 Smart transmitter can be configured for reverse output through a HART-Compatible P1 Hydrostatic Testing Interface.

Each transmitter is hydrostatic tested according to Table 12. V2 1 .n Test Resistor

Test medium Is water.

A 1 0 precision resistor Is mounted across the test terminals

This option provided for transmitters with remote diaphragm to provide 4-20 mV output or a 10-50 mV output If 10-50 mA seal on application only. output Is used.

Rosemount Procedure 1746 outlines the testing procedure.

This option cannot be used with any meter options or Option P2 Cleaning for Special Service Codes 15 or 16. *

This option minimizes contaminants to the process system by V3 5 .n Test Resistor cleaning wetted surfaces with a suitable detergent.

A 5 n precision resistor Is mounted across test terminals to

Rosemount Procedure 97412 outlines the cleaning procedure. provide 20-100 mV output or a 50-250 mVoutput If 10-50 P3 Cleaning for <1 PPM Chlorlne/Fluorine mA output is used.

This optlon cannot be used with any meter options or Option Codes 15or16.

25

Calculation PM-1209 Revision o Product Data Sheet Attachment C 00813-0100-4360, Rev JB Page C26 of C28 Rosemount 1151 March 2010 Rosemount 1151 Configuration Data Sheet

= Select only one of the items provided

'OLD

=Default Required Value 8One or more of the listed Items can be selected Customer Information Customer: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ContactName: _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Phone No: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Fax No./Email: - - - - - - - - - - - - - - - -

P.O./Reference No.: _ _ _ _ _ _ _ _ _ _ _ _ _ P.O. Line I t e m : - - - - - - - - - - - - - - - -

Quote No. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Model No.=----------'"---------

Customer Slgnoff:

Output Information 4mA::i o*

20mA= Upper Range Limit*

Units:: QlnH20* Qpsl QPa 0 mmH20 al 4 °C QinHg Obar QkPa Q1nH20 at 4 °C OftH20 Ombar QTorr psi for Ranges ~ In.

OmmH20 Qg/cm2 QAtm

lnH 20 for Ranges 3-5 in.

QmmHg 0 kgtcrn2 QMPa Output= 0 Linear* 0 Square Root NOTE Custom configuration information below this line requires C9 option code.

Transmitter Information Descriptor: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (16 characters)

Message: (32 characters)

Date: (Date of Calibration*>

26

Product Data Sheet Calculation PM-1209 Revision O 00813R01 OOR4360, Rev JB Attachment C March 2010 Page C27 of C28 Rosemount 1151 Signal Sefection 0 4-20 mA with simultaneous digital signal based on HART protocol*

0 Burst mode of HART digital process variable Burst mode output options:

0 Primary variable O Primary variable In percent of range and mA O All dynamic variables In engineering units O All dynamic variables In engineering units and the primary variable mA value 0 Multidrop Communication Transmitter Address (1-15): __ (default= 0)

... '~.

27

Calculation PM-1209 Revision O Product Data Sheet Attachment C 00813-0100-4360, Rev JB Page C28 of C28 Rosemount 1151 March 2010 Standard Tenns and Conditions of Sale can be found at www.rosemountcom\terms of sale The Emerson logo Is a trademark and service mark of Emerson Electric Co. - -

Rosemount, Annubar, ProPlate, and the Rosemount logotype are registered trademarks of Rosemount Inc.

HART is a registered trademark of the HART Communication Foundation. 8-Cell Is a trademark of Rosemount Inc.

Fluoro/ube Is a registered trademark of Hooker Chemical Co.

Vlton is a registered trademark of E.1. du Pont de Nemours & Co.

Neobee M-20 Is a registered trademark of Stepan Chemical Co.

Sy/therm and D.C. are registered trademarks of Dow Corning Corp.

Aflas ls a registered trademark of Asahi Glass Co., Ud.

Kynar ls a trademark of Pennwalt Inc..

o

Emerson Process Management Emerson Process Management Emerson FZE Emerson Process Management Asia Pacific Rosemount Measurement Blegrstrasse 23 P.O. Box 17033 Pte Ltd 8200 Market Boulevard P.O. Box 1046 Jebel All Free Zone 1 Pandan Crescent Chanhassen MN 55317 USA CH 6341 Baar Dubai UAE Singapore 128461 Tel (USA) 1 800 999 9307 Switzerland Tel +971 4 811 8100 Tel +65 en1 a211 Tel (International) +1 952 906 8888 Tel +41 (0) 41 768 6111 Fax +971 4 886 5465 Fax +65 an1 0947 Fax +1 952 949 7001 Fax +41 (0) 41 768 6300 Service Support Hotline : +65 6770 8711 Email : Enquiries@AP.EmersonProcess.com EMERSON~

f 00813-0100-4360 Rev JB. 3/10 Process Management

Calculation PM-1209 Revision 0

.,.. ,,,. .....,...... Attachment D Page 01 of 02

r Anaiog to Digital Converter Card RTP 843612X PRODUCT HIGHUGKfS

~

..!,

High-speed . .log slpl 11111tlplelq

W'lle-lange signal capabllftr I

.,.... .

12ar14-bit bipolar or 1ripol* ND COllWJl'Sion

164it bipols AID comersiGn

Dlleldal *sil9& ended input capability

* .... * *

cali~ eperatm PRODUCT OVERVIEW The RTP 8436/2X Series Analog to Digital Con- RTP 8436/2X, Analog to .Digital convener Card verter Card.was designed to be foDn-> fit, and func..

tionality compatt"ble with the RTP 7436/ZX card. and the 16-bit AID Converter operates at 32,400 s/sec.

This card demonstrates RTP's commitment.to it's * . Each AID Converter baa a programmable amplifier non-obsolescence policy. Like its predecessor., this with gain ranges of 1, 2, 4, or 8. The AID Converter cant provides tow..cost, multiplo-cbanuel analog cant accepts single-ended or dilfermtial inputs 111lder input capability to RTP Universal VO Subsystellla.

user progmm control. AID Converter cards am user The catd set can be used in conjWlction widl digital configurable to accept pulses to synchronize data inpntloulput ~analog output caxds, and special fwacti.on cards to provide substantial vcmtilfty in a conversions to an cxtema1 clock.

single chassis. The card set bandies input signals, whether they ue low..levcl, bigh-leve~ wide-range, 1tE R1P COMMITMENT or any combination ftom a wide variety of standard SUperior Reliability .

transduceis such as tber.m.ocoup1es, RTD's, and R.TP products have been engineered to provide high pressmc transducers. retiabilif:Y mthe 1e14 The .Analog to D.igita1 A singlo AID Converter card can perform conver-

C<mverter Card is desipcd 10 tho same standanls as sions for up to 15 Universal Ga~ Cards with any odtcr RTP products which have been q~lified under combination of Relay Trausfonner-Coupled, or the demanding Class IE Nuclear Safety guidelines Solid-State Cards. The AID Converter card pxovides established by the Nuclear Regulatobr ComniissiOL a maximum of240 singlo-ended channels or 120 RTP's exacting product standards xJsu1t in minbnal differential c~ls per RTP Univenat I/O Sub- system downtime, wariy nee maintenance, and a system chassis. Single-ended and differential chan- high retum OD mvestme~

nels can be inteunixed. Similarly, Relay Gate Catds,

Tnnsformer-Coupled Gam cams, and Solid-State Engineering SUpport Gate Cards can be intemtixed in a system configura- RTP piovides ot1'-1he-shelf dcliveiy as well as tion. cu.stom.oeoginecred solutions. R'IP also backs each ol AID Converter cards are available in three con.. its products with full technical support and complete figurations to fi11fill the speed and accuracy~ documeolation. Call your RTP iepresentative for mentsofmostusem. Either 12-bitor 14.bit, succes- additional infonnati~ specifications, and prlces.

sive approximation AID Conveilers can be specified Non.Obsolescence Policy with a choice ofbipolar or unipolar inpots. The input J:a addition to an outslallding 3-Year Warranty, it is for the 16--bit ooaverter is bipolar. 1he policy ofRTP Coip. to support i1s pxoducts The output data format is 2's oomplement, sign thmogh 1he normal life span of the plant or equip-extended. Two 12-bit speed versions ofthe cud are ment. Only R.TP offers this level of support for its available to provide a standard speed widi a maxi.. products.

mum rate of 25,000 samples per second (slsec) or a high speed version of 50,000 s/sec. The 14-bit AID Converter operates at sample rates of 38,000 s/sec, RTP r.orp. 2705 Gateway Drive Panpano Beach. Florida 33069 PHONE (9~) 97.f-5500 fAX {954) 975.Q815 INTERNET: http://www.rtpcoqJ.mn EMAIL rtPnfot!npcorp.com

.. Calculation PM-1209-Revision 0 i Attachment D Page 02 of D2 SPECIFICATIONS . Model Variations The Analog to D.igi.181 Converter Catd is available in Gain Accuracy acvo.ml variations to suit application specifio require-12..bit: ::l-0.025% offidl-scale, :l::SOppmf'C. ments:

14-bit: :l:0.0125% offull-scale, *50ppml°C. 12-Bit' 16-bit: =tl.00625% of ibll-scale, :l::SOppml°C.

Standard Speed or High Speed Power Requirements

Unipolar or Bipolar

+5 VDC @475 mA

Binaly to 10.24 VFS

+15 VDC@SS mA

Decimal to 10.00 VFS

-IS VDC @SS mA 14-Blt Environmental

Unipolar or Bipolar Opera1ing Temperature :Range: OOC to +5S9C

Binary to 10.24 VFS Stonge .l)~CUre Range: -200C ,ql:!~.~!C.-:*~****-** ~ .. .~~~.~-!0~~ ~~- *-.. . -****

RelativeHmiddityRange:20%to80%,~~- t"(;;Brr~r--*--* ......--. -*******-*--:'*~ .. - - * -*** **-*..

Bipolar

Binary to 10.24 VFS

Decimal to 10.00 VPS RTP offers a complete line of Data Acquisition and Process Control Systems. Contact RTP with your most challenging requii'elllents and let us explain how we can meet your specific needs.

CaJculation PM-1209 Revision 0 i

Attachment E Page E1 of E1 Jenny Regan From: dave.mccully@rtpcorp.com Sent: Friday, May 10, 2002 9:03 AM

'°'-"To: jenregan@comcast.net Cc: don.chase@rtpcorp.com: sal.provanzano@rtpcorp.eom; jack.sloan@rtpcorp.com

Subject:

Ref2]:Need info on RTP components for Exelon Jennife:r, There a:ce 2 types of errors introduced by'the 038-0012-X!Z 4-Channel, J*Nire RTD Bridge Card.

1. Adjustment: To get the most accuLate readings, you need to adjust the gain and offset includinq t.he field wire. You will need to do precision resistance substitution where the RTD is located and then adjust the gain and offset of the Bridge card. This is because the lead resistance becomes part of the bxidqe circuit. cards are shipped from the factory adjusted for nea~ ze~o ohm cables.

2. Temperature: The combined effects of the power supply and resistor temperature drift is ~-80 PPM/Degree c.

The accuracy of the 7435/50 (021-5234) Gate card and 8436/21 14-Bit A/D Convertex has 2 components. Note that the A/D is required as the gate card by itself pexforms no function.

The 160 mv range is mentioned because the bridge cards are usually designed to put out 100 mv for the upper temperature of the specified range.

1. static Accuracy: +-0.0638t of full scale on the 160 mv range.

2. Temperature: +-0.013' of full scale per Degrees c on the 160 mv range.

~

If you need any additional information, please feel free to contact us.

Regards, David Mccully, Applications Engineer RTF Corp.

1834 SW 2 Street Pompano Beach, FL 33059 Phone: Direct (954) 984-7203 or (954)-9=7*4-5500, Extension 7203 FAX: (95~) 975-9815 E Mail: dave.mcoully@rtpcorp.com Inte~net: http://www.rtpcorp.com

__,__~------~~~Reply Separator______--=~~---i:~~

Subject:

Re:Need info on RTP components for Exelon Author: Don Chase Date: 5/9/02 1:31 PM Mr. Chase; Please Ieply to this email ox give me a call reqardin9 accuraey"spe.cifications on the following RTP parts at Peach Bottom nuclear plant:

RTP 038-00120154, signal conditioning card fox 100 ohm RTD input RTP 021-5234-00(last digit illegible), analoq input card fo~ signal conditioning unit output, to diqital computer input.

I could not find these part numbers on your web site. Thanks in advance for you~ help.

1

ROSEMOUNT. . :-~~o* Calculation PM-1209 Revision O Attachment F itasemount Inc.

z~cn T'~nl'IOI09Y Or1v1t

=::en Pr&tflf, MN 553~.a U S A.

--!11&121 9,.1.ssa.o Page F1 of F2 *eltx *3100\2

~ ... 1612\ 828*3088 June 24, 1991 Mr. Ed Kaczmorski Commonwealth Edison Co.

Nuclear Engineerinq 1400 OPUS Place, Suite 400 Downers Grove, IL 60515 Re: Pressure Transmitter Performance Specifications

Dear Mr. Kaczmorski,

Per your request, the following information is forwarded to clarify the performance specifications of Rosemount commercial grade and nuclear qualified instrumentation.

Rosemount Nuclear Qualified instrumentation applicable to Commonwealth Edison Plants are tna Model 1152, 1153 Series B, 1153 Series D, 1154 and li54 series H Pressure Transmitters; Model JSJC Conduit seal.s; and the Model 7lOOU Trip/Calibration System. The sr. :~~cifications referenced in Rosemount literature are separa~ad

into 'Nuclear Specifications' which include ** the DBE simulation and

'Performance Specifications.1 which incluQ.e transmitter performance under plant reference conditions.

The 'Nuclear Specifications' whi.ch include Radiation, seismic, LOCA/HELB, and Post DBE are derived from the Type Testinq completed on each*model type. Due to the limit~d.

sample size in the Type Tests, these specifications are based on worst case errors plus margin as referenced in IEEE 323-1974 (1983). For most practical purposes, these specifications are considered 2-sigma~ (TWo standard deviations).

The 'Performance ~pacifications' are determined from testing completed on. large samples of each model type. In ~ddition, all manufactured units are tested to insure m*e etinq published specifications prior ~o shipment. Therefore, these specifications are considered 3-siqma. (Three standard deviations)

There is one exception to this rule. The Point *orift Specification of ~.20% URL for 24 Months which repl~ces the stability specification of +;-.2s~ URL for 6 mon'\:hs for all nuclear transmitters is considered to be 2-sigma based on the sample size used during testing.

nOS!mount lnc.

Z0o1 Tecnno1cav Ot*v~

!.:on Pr;i111e. MN ~5344 U.S:.A Calculation PM-1209-Revision O Attachment F Page F2 of F2 Page 2 of 2 Commercial Grade Instrumentation:

The specifications published for Rosemount commercial grade instrumentations are considered to be* 3-$iqma. All Mode.l 1151 Transmitters, 444 Temperature Transmitters and related hardware specifications were based on testing of very large sample sizes. In addition, most all specifications are verified during manufacturing *of the in~truments.

Specifications written as +/- for both Nuclear and Commercial Grade instrumentation implies random uncertainty allowances within the specification band. These specifications are normally distr~huted for most pr~ctical pui;posaa;.

We anticipate this information will assist you in the interpretation of Rosemount speci=ications. If we can be of further assistance, please do *not hesitate to contact us.

sincerely, ,

~)~

?-;7. '-! Zy Timothy J. t;ayer Marketing Engineer Rosemount Nuclear Products cc: N. Hyrniw #7 TJ'L

ATTACHMENT 5 License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 License Amendment Request - Expanded Actions for LEFM Conditions Cameron Affidavit Supporting Withholding Attachment 4 from Public Disclosure

Caldon Ultrasonics Technology Center 1000 McClaren Woods Drive Coraopolis, PA 15108 Tel +1 724-273-9300 Fax +1 724*273*9301 August 3, 2018 CAW 18-07 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Cameron Engineering Report ER-464 Rev. 9 "Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 2 Using the LEFM ~ + System" Gentlemen:

This application for withholding is submitted by Cameron (Holding) Corporation, a Nevada Corporation (herein called "Cameron") on behalf of its operating unit, Caldon Ultrasonics Technology Center, pursuant to the provisions of paragraph (b) (1) of Section 2.390 of the Commission's regulations. It contains trade secrets and/or commercial information proprietary to Cameron and customarily held in confidence.

The proprietary information for which withholding is being requested is identified in the subject submittal. In conformance with 10 CFR Section 2.390, Affidavit CAW 18-07 accompanies this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.

Accordingly, it is respectfully requested that the subject information, which is proprietary to Cameron, be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference CAW 18-07 and should be addressed to the undersigned.

j;_=JM Joanna Phillips Nuclear Sales Manager Enclosures (Only upon separation of the enclosed confidential material should this letter and affidavit be released.)

Schlumberger-Private

August 3, 2018 CAW 18-07 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

SS COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Joanna M. Phillips, who, being by me duly sworn according to law, deposes and says that she is authorized to execute this Affidavit on behalf of Cameron Holding Corporation, a Nevada Corporation (herein called "Cameron") on behalf of its operating unit, Caldon Ultrasonics Technology Center, and that the averments of fact set forth in this Affidavit are true and correct to the best of her knowledge, information, and belief:

Signed and sworn to before me this *?xJ. day of A~ .2010 J,AAM!AQ A. b.i~

Notary Public C MONWEALTH OF P NNSVLVANIA NOTARIAL SEAL Frances A. Lewis, Nota/y Public Coraopolis Boro, Alleghen~ County My Commission Expires Nov. 25, 2018 R, P 11118YL AlllA ASSOCIATION OF NOTARIES 1

Schlumberger-Private

August 3, 2018 CAW 18-07

1. I am the Director of Business Development for Nuclear and Defense Markets of Caldon Ultrasonics Technology Center, and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of Cameron.

2. I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Cameron application for withholding accompanying this Affidavit.

3. I have personal knowledge of the criteria and procedures utilized by Cameron in designating information as a trade secret, privileged or as confidential commercial or financial information.

4. Cameron requests that the information identified in paragraph S(v) below be withheld from the public on the following bases:

Trade secrets and commercial information obtained from a person and privileged or confidential The material and information provided herewith is so designated by Cameron, in accordance with those criteria and procedures, for the reasons set forth below.

5. Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, 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 Cameron.

(ii) The information is of a type customarily held in confidence by Cameron and not customarily disclosed to the public. Cameron has a rational basis for determining the 2

Schlumberger-Private

August 3, 2018 CAW 18-07 types of information customarily held in confidence by it and, in that connection utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Cameron policy and provides the rational basis required. Furthermore, the information is submitted voluntarily and need not rely on the evaluation of any rational basis.

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 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 Cameron's competitors without license from Cameron 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, and assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Cameron, its customer or suppliers.

(e) It reveals aspects of past, present or future Cameron or customer funded development plans and programs of potential customer value to Cameron.

(t) It contains patentable ideas, for which patent protection may be desirable.

3 Schlumberger-Private

August 3, 2018 CAW 18-07 The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (a), (b) and (c), above.

There are sound policy reasons behind the Cameron system, which include the following:

(a) The use of such information by Cameron gives Cameron a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Cameron competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Cameron ability to sell products or services involving the use of the information.

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

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

(e) Unrestricted disclosure would jeopardize the position of prominence of Cameron in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Cameron capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence, and, under the provisions of 10 CFR §§ 2. 390, it is to be received in confidence by the Commission.

4 Schlumberger-Private

August 3, 2018 CAW 18-07 (iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld is the submittal titled:

Cameron Engineering Report ER- 464 Rev. 9 "Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 2 Using the LEFM., +System"

Table of Contents page ii contains partial proprietary information

Pages 1, 2, 4, 5 contain partial proprietary information

Appendix A Table of Contents contains partial proprietary information

Appendix A.4, A.5, B.2, C.1 and C.2 Cover Pages contains partial proprietary information

Appendices A.1, A.2, A.4, A.5, B.1, B.2, C.1 and C.2 are proprietary in their entirety It is designated therein in accordance with 10 CFR §§ 2.390(b)(l)(i)(A,B), with the reason(s) for confidential treatment noted in the submittal and further described in this affidavit. This information is voluntarily submitted for use by the NRC Staff in their review of the accuracy assessment of the proposed methodology for the LEFM CheckPlus System used by Peach Bottom Atomic Power Station for flow measurement at the licensed reactor thermal power level of 4016 MWt.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Cameron because it would enhance the ability of competitors to provide similar flow and temperature measurement systems 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 the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Cameron effort and the expenditure of a considerable sum of money.

In order for competitors of Cameron to duplicate this information, similar products would have to be developed, similar technical programs would have to be performed, and a significant 5

Schlumberger-Private

August 3, 2018 CAW 18-07 manpower effort, having the requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods.

Further the deponent sayeth not.

6 Schlumberger-Private

Caldon Ultrasonics Technology Center 1000 Mcclaren Woods Drive Coraopolis, PA 15108 Tel +1 724*273-9300 Fax +1 724*273-9301 August 3, 2018 CAW 18-08 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Cameron Engineering Report ER-463 Rev. 8 "Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 3 Using the LEFM -1 +System" Gentlemen:

This application for withholding is submitted by Cameron (Holding) Corporation, a Nevada Corporation (herein called "Cameron") on behalf of its operating unit, Caldon Ultrasonics Technology Center, pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Commission's regulations. It contains trade secrets and/or commercial information proprietary to Cameron and customarily held in confidence.

The proprietary information for which withholding is being requested is identified in the subject submittal. In conformance with 10 CFR Section 2.390, Affidavit CAW 18-08 accompanies this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.

Accordingly, it is respectfully requested that the subject information, which is proprietary to Cameron, be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference CAW 18-08 and should be addressed to the undersigned.

Ver ::~

oanna Phillips Nuclear Sales Manager Enclosures (Only upon separation of the enclosed confidential material should this letter and affidavit be released.)

Schlumberger-Private

August 3, 2018 CAW 18-08 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

SS COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Joanna Phillips, who, being by me duly sworn according to law, deposes and says that she is authorized to execute this Affidavit on behalf of Cameron Holding Corporation, a Nevada Corporation (herein called "Cameron") on behalf of its operating unit, Caldon Ultrasonics Technology Center, and that the averments of fact set forth in this Affidavit are true and correct to the best of her knowledge, information, and belief:

~

Nuclear Sales Manager Signed and sworn to before me this -,ct\ day of

~ 2018 J,~A - ~.u~

Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Frances A. Lewis, Notary Public Coraopolis Boro, Allegheny County My Commission Expires Nov. 25, 2018 IEIBER, PENllSYLYAIUA ASSOCIATION OF NOTARIES 1

Schlumberger-Private

August 3, 2018 CAW 18-08

1. I am the Nuclear Sales Manager of Caldon Ultrasonics Technology Center, and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of Cameron.

2. I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Cameron application for withholding accompanying this Affidavit.

3. I have personal knowledge of the criteria and procedures utilized by Cameron in designating information as a trade secret, privileged or as confidential commercial or financial information.

4. Cameron requests that the information identified in paragraph S(v) below be withheld from the public on the following bases:

Trade secrets and commercial information obtained from a person and privileged or confidential The material and information provided herewith is so designated by Cameron, in accordance with those criteria and procedures, for the reasons set forth below.

5. Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, 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 Cameron.

(ii) The information is of a type customarily held in confidence by Cameron and not customarily disclosed to the public. Cameron has a rational basis for determining the types of information customarily held in confidence by it and, in that connection utilizes a 2

Schlumberger-Private

August 3, 2018 CAW 18-08 system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Cameron policy and provides the rational basis required. Furthermore, the information is submitted voluntarily and need not rely on the evaluation of any rational basis.

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 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 Cameron's competitors without license from Cameron 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 ofresources or improve his competitive position in the design, manufacture, shipment, installation, and assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Cameron, its customer or suppliers.

(e) It reveals aspects of past, present or future Cameron or customer funded development plans and programs of potential customer value to Cameron.

(f) It contains patentable ideas, for which patent protection may be desirable.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (a), (b) and (c), above.

3 Schlumberger-Private

August 3, 2018 CAW 18-08 There are sound policy reasons behind the Cameron system, which include the following:

(a) The use of such information by Cameron gives Cameron a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Cameron competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Cameron ability to sell products or services involving the use of the information.

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

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

(e) Unrestricted disclosure would jeopardize the position of prominence of Cameron in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Cameron capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence, and, under the provisions of 10 CFR §§ 2. 390, it is to be received in confidence by the Commission.

4 Schlumberger-Private

August 3, 2018 CAW 18-08 (iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld is the submittal titled:

Cameron Engineering Report ER- 463 Rev. 8 "Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 3 Using the LEFM.., +System"

Table of Contents page ii contains partial proprietary information

Pages 1, 2, 4, 5 contain partial proprietary information

Appendix A Table of Contents contains partial proprietary information

Appendix A.4, A.5, B.2, C. l and C.2 Cover Pages contains partial proprietary information

Appendices A.1, A.2, A.4, A.5, B.1, B.2, C. l and C.2 are proprietary in their entirety It is designated therein in accordance with 10 CFR §§ 2.390(b)(l)(i)(A,B), with the reason(s) for confidential treatment noted in the submittal and further described in this affidavit. This information is voluntarily submitted for use by the NRC Staff in their review of the accuracy assessment of the proposed methodology for the LEFM CheckPlus System used by Peach Bottom Atomic Power Station for flow measurement at the licensed reactor thermal power level of 4016 MWt.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Cameron because it would enhance the ability of competitors to provide similar flow and temperature measurement systems 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 the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Cameron effort and the expenditure of a considerable sum of money.

In order for competitors of Cameron to duplicate this information, similar products would have to be developed, similar technical programs would have to be performed, and a significant 5

Schlumberger-Private

August 3, 2018 CAW 18-08 manpower effort, having the requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods.

Further the deponent sayeth not.

6 Schlumberger-Private

ATTACHMENT 6 License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 License Amendment Request - Expanded Actions for LEFM Conditions Cameron ER-464NP, " Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 2 Using the LEFM + System," Revision 9 (Non-Proprietary Version), and ER-463NP," Uncertainty Analysis for Thermal Power Determination at Peach Bottom Unit 3 Using the LEFM + System," Revision 8 (Non-Proprietary Version)

Measurement Systems CaldronUltrasonics Engineering Report: ER-464NP Revision 9 UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT PEACH BOTTOM .

UNIT 2 USING THE LEFM./+ SYSTEM Prepared by: Ryan Hannas Reviewed for Proprietary Info: Joanna Phillips Approved by: Bobbie Griffith August 2018 Schlumberger-Private

Measurement Systems

© 2018 Cameron. All information contained in this publication is confidential and proprietary property of Cameron. Any reproduction or use of these instructions, drawings, or photographs without the express written permission of an officer of Cameron is forbidden.

Printed in the United States of America.

Engineering Report No. ER-464P, Rev 9 August2018 Schlumberger-Private

Measurement Systems Engineering Report: ER-464NP Revision 9 UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT PEACH BOTTOM UNIT 2 USING THE LEFMv"'+ SYSTEM Table of Contents

1.0 INTRODUCTION

2.0

SUMMARY

3.0 APPROACH 4.0 OVERVIEW

5.0 REFERENCES

6.0 APPENDICES A Information Supporting Uncertainty in LEFMv"'+Flow and Temperature Measurements A.1 LEFMv"'+Inputs A.2 LEFM v"'+ Uncertainty Calculations A.3 LEFMv"'+ Spool Piece(s) Meter Factor and Meter Factor Uncertainty Trade A.4 [ ] Secret&

Confidential A.5 [ ] Commercial Information B Total Thermal Power Uncertainty B.1 Thermal Power Uncertainty Calculation using the LEFM~+ System Trade B.2 Thermal Power Uncertainty Calculation using the LEFM~+ System Secret &

Confidentic:

[ ] Commercic:

lnformatior c Total Thermal Power Uncertainty C.1 Thermal Power Uncertainty Calculation [ Trade

] Secret &

Confidenti<

C.2 Thermal Power Uncertainty Calculation [ Commerci; lnformatior

]

[ ]

Schlumberger-Private

Measurement Systems

1.0 INTRODUCTION

The LEFM ../ and LEFM ../+ 1 are advanced ultrasonic systems that accurately measure the volume flow and temperature of feedwater in nuclear power plants. Using a feedwater pressure signal input to the LEFM ../ and LEFM ../ + mass flow is determined. The mass flow and temperature outputs are used, along with other plant data, to compute reactor core thermal power. The technology underlying the LEFM ../ ultrasonic instruments and the factors affecting their performance are described in a topical report, Reference I, and a supplement to this topical report, Reference 2.

The LEFM../+,which contains two LEFM../'s, is described in another supplement to the topical report, Reference 3. The exact amount of the uprate allowable under a revision to 10CFR50 Appendix K depends not only on the accuracy of the LEFM ../ + outputs but also on the uncertainties in other inputs to the thermal power calculation.

It is the purpose of this document to provide an analysis of the uncertainty contribution of the Trade LEFM ../+ System to the overall thermal power uncertainty at Peach Bottom Unit 2. [ Secret &

Confidential Commercial Information This report addresses three specific operating conditions:

Trade Secret &

Confidenti<

Commerci<

lnformatior The uncertainties in LEFM mass flow and feed water temperature are used in the calculation of the thermal power uncertainty due to the LEFM ../ + (Appendix B). This appendix complies to the methodology of the Topical Report (References 1 and 2) and provides the bound for the uncertainty Trade uprate that the plant may recognize. [ Secret&

Confidentia Commercia Information

] A detailed discussion of the methodology for combining these terms is described in Reference 3.

Trade Secret &

This analysis is a bounding analysis for Peach Bottom Unit 2. [ Confidential Commercial

] Information The uncertainties in these values are bounded by this analysis.

Trade Secret &

Confidential Commercial Information ER-464NP Rev 9 Prepared by: RSH Reviewed by: BWG Schlumberger-Private

Measurement Systems 2

2.0

SUMMARY

The uncertainty approach is documented in Reference 3. The Maintenance Mode uncertainty results below use the conservative plane balance term found in Appendix A.2.

1. Mass Flow Uncertainty The uncertainty in the LEFMv" +'s system mass flow is as follows:

o All meters in Normal Mode,+/- 0.30%

0 [ ] Trade Secret &

0 [ ] Confidential Commercial 0 [ ] Information 0 [ ]

Trade Secret &

Confidential Commercial Information

2. Temperature Uncertainty The uncertainty in the LEFM v" + feedwater temperature is as follows: Trade Secret &

Confidential 0 [ ] Commercial 0 [ ] Information 0 [ ]

0 [ ]

3. Thermal Power Uncertainty The thermal power uncertainty approach is documented in Reference 3 and Appendix B of this document. The total uncertainty in the determination of thermal power related to the LEFM v" +

system is as follows :

o All meters in Normal Mode, +/- 0.34%

0 [ ]

0 [ ] Trade Secret &

0 [ ] Confidential Commercial Information Trade Secret &

Confidentia Commercia Information ER-464NP Rev 9 Prepared by: RSH Reviewed by: BWG Schlumberger-Private

Measurement Systems 3

3.0 APPROACH All errors and biases are calculated and combined according to the procedures defined in Reference 4 and Reference 5 in order to determine the 95% confidence and probability value. The approach to determine the uncertainty, consistent with determining set points, is to combine the random and bias terms by the means of the RSS approach provided that all the terms are independent, zero-centered and normally distributed.

Reference 4 defines the contributions of individual error elements through the use of sensitivity coefficients defined as follows:

A calculated variable Pis determined by algorithm f, from measured variables X, Y, and Z.

P "" f (X, Y, Z)

The error, or uncertainty in P, dP, is given by:

dP = _ff_I dx +if I dr +if I dz ox yz OY xz 8Z XY As noted above, Pis the determined variable--in this case, reactor power or mass flow-- which is calculated via measured variables X, Y, and Z using an algorithm f (X, Y, Z). The uncertainty or error in P, dP, is determined on a per unit basis as follows:

dP = {x _ff_I }dx P POXyz X

+{r if I POYxz

}dr Y

+{z ifl P8Zxr

}dz Z

where the terms in brackets are referred to as the sensitivity coefficients.

If the errors or biases in individual elements (dXIX, dYIY, and dZIZ in the above equation) are all caused by a common (systematic) boundary condition (for example a common instrument) the total error dP/P is found by summing the three terms in the above equation. If, as is more often the case, the errors in X, Y, and Z are independent of each other, then Reference 4 recommends and probability theory requires that the total uncertainty be determined by the root sum square as follows (for 95% confidence and probability):

Obviously, if some errors in individual elements are caused by a combination of boundary conditions, some independent and some related (i.e., systematic) then a combination of the two procedures is appropriate.

ER-464NP Rev 9 Prepared by: RSH Reviewed by: BWG Schlumberger-Private

Measurement Systems 4

4.0 OVERVIEW The analyses that support the calculation of LEFM ./+uncertainties are contained in the appendices to this document. The functions of each appendix are outlined below.

Appendix A.l, LEFM,.I'+Inputs This appendix tabulates dimensional and other inputs to the LEFM ./+ which is used for the computation of mass flow and temperature. [ Trade Secret &

Confidential

] are used in this appendix. Commercial Information Appendix A.2, LEFM,.I'+Uncertainty Calculations This appendix calculates the uncertainties in mass flow and temperature as computed by the LEFM ./+ using the methodology described in Appendix E of Reference 1 and Appendix A of Reference 33 , with uncertainties in the elements of these measurements bounded as described in both references 4 . The spreadsheet calculation draws on the data of Appendix A. I for dimensional information. [

Trade Secret &

Confidential Commercial Information This appendix utilizes the results of the calibration testing for the plant spool piece(s) for the uncertainty in the profile factor (calibration coefficient). The engineering reports for the spool piece calibration tests are referenced in Appendix A.3 to this report.

Appendix A.3, Meter Factor and Meter Factor Uncertainty The calibration test report for the spool piece(s) establishes the overall uncertainty in the meter (profile) factor of the LEFM./ +.The elements of the meter factor uncertainty include Trade

[ Secret &

Confidentia

] are also Commercia Information elements in establishing the uncertainty in meter factor.

Trade Secret &

Confidential Commercial Information 3

Reference 3 (ER l 57P) develops the uncertainties for the LEFM ./+ system. Because this system uses two measurement planes, the structure of its uncertainties differs somewhat that of an LEFM ./.

4 Reference 3 (ER l 57P) revised some of the time measurement uncertainty bounds. The revised bounds are a conservative projection of actual performance of the LEFM hardware. ER SOP used bounds that were based on a conservative projection of theoretical performance.

ER-464NP Rev 9 Prepared by: RSH Reviewed by: BWG Schlumberger-Private

Measurement Systems 5

[

]

[

Trade Secret &

Confidentia Commercia lnfonnation

[

Trade Secret&

Confidentia Commercia lnfonnation

]

Appendix A.4, [

Trade Secret &

Confidential

] Commercial lnfonnation Appendix A.5, [

Trade Secret &

Confidential Commercial lnfonnation Appendix B, Total Thermal Power Uncertainty using the LEFM ./+

The total thermal power uncertainty for a plant using the LEFM ./+ system is calculated in this appendix. It combines the results provided in Appendix A, along with plant specific terms (ex., steam enthalpy, moisture carryover, etc.).

These terms have been combined in a method consistent with that described in the Topical Report and its supplements (References 1, 2, and 3). Appendix B reconciles the results of this analysis with ERi 57(P-A) Rev. 8 (Reference 3).

Appendix C, Total Thermal Power Uncertainty [

Trade

] Secret &

Confidential Appendix C has a special calculation for Peach Bottom [ Commercial lnfonnation

]

ER-464NP Rev 9 Prepared by: RSH Reviewed by: BWG Schlumberger-Private

Measurement Systems 6

5.0 REFERENCES

1) Cameron Topical Report ER-80P, "Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM Check System, dated March 1997, Revision 0

2) Cameron Engineering Report ER-160P, "Supplement to Topical Report ER 80P: Basis for a Power Uprate with the LEFM System, dated May 2000, Revision 0

3) Cameron Engineering Report ER-157(P-A), "Supplement to Caldon Topical Report ER-80P: Basis for Power Uprates with an LEFM Check or an LEFM CheckPlus, dated May 2008, Revision 8

4) ASME PTC 19.1, Measurement Uncertainty

5) Caldon Engineering Report ER-590, "The Effects of Random and Coherent Noise on LEFM CheckPlus Systems, Rev. 2 ER-464NP Rev 9 Prepared by: RSH Reviewed by: BWG Schlumberger-Private

Measurement Systems Appendix A Appendix A.1, LEFM ./+ Inputs Appendix A.2, LEFM./+ Uncertainty Calculations Appendix A.3, LEFM./+ Spool Piece(s) Meter Factor and Meter Factor Uncertainty Trade Appendix A.4, [ Secret &

Confidential Commercial Appendix A.5, [ Information Schlumberger-Private

Measurement Systems Appendix A.1 LEFM ./+ Inputs No Attachment to follow, as Appendix is Proprietary in its Entirety Schlumberger-Private

Measurement Systems Appendix A.2 LEFM,(+Uncertainty Calculations No Attachment to follow, as Appendix is Proprietary in its Entirety Schlumberger-Private

Measurement Systems Appendix A.3 LEFM,(+Spool Piece(s) Profile Factor and Profile Factor Uncertainty Reference Caldon Engineering Reports ER-441 Rev 1, "Profile Factor Calculation and Accuracy Assessment for the Peach Bottom Unit 2 Replacement LEFM v" + Spool Pieces, August 2016 Schlumberger-Private

Measurement Systems Appendix A.4 Trade Secret &

I Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety Schlumberger-Private

Measurement Systems Appendix A.5 Trade Secret &

Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety Schlumberger-Private

Measurement Systems Appendix B-1 Thermal Power Uncertainty Calculation using the LEFM,(+ System No Attachment to follow, as Appendix is Proprietary in its Entirety Schlumberger-Private

Measurement Systems Appendix B-2 Thermal Power Uncertainty Calculation using the LEFM,(+System Trade Secret &

[ J Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety Schlumberger-Private

Measurement Systems Appendix C-1 Trade Thermal Power Uncertainty Calculation [ Secret&

Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety Schlumberger-Private

Measurement Systems Appendix C-2 Thermal Power Uncertainty Calculation [ Trade Secret&

Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety Schlumberger-Private

Valves & Measurement Sales HEADQUARTERS +1 .281.582.9500 (HOUSTON, TX, USA) measurement@c-a-m.com Service CANADA +1.403.291.4814 MIDDLE EAST & NORTH AFRICA +971.4802.7700 ms-services@c-a-m.com LATIN AMERICA +54.11.5070.0266 EUROPE, CASPIAN, RUSSIA +44.1892.518000 INDIA & SOUTH AFRICA

+91 .9903822044 ASIA PACIFIC +603.7954.0145 www.cameron.slb.com Schlumberger-Private

Measurement Systems Caldon Ultrasonics Engineering Report: ER-463NP Revision 8 UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT PEACH BOTTOM UNIT 3 USING THE LEFM./+ SYSTEM Prepared by: Ryan Hannas Reviewed for Proprietary Info: Joanna Phillips Approved by: Bobbie Griffith August 2018

Measurement Systems

© 2018 Cameron. All information contained in this publication is confidential and proprietary property of Cameron. Any reproduction or use of these instructions, drawings, or photographs without the express written permission of an officer of Cameron is forbidden.

Printed in the United States of America.

Engineering Report No. ER-463NP, Rev 8 August2018

Measurement Systems Engineering Report: ER-463NP Revision 8 UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT PEACH BOTTOM UNIT 3 USING THE LEFM,f+SYSTEM Table of Contents

1.0 INTRODUCTION

2.0

SUMMARY

3.0 APPROACH 4.0 OVERVIEW

5.0 REFERENCES

6.0 APPENDICES A Information Supporting Uncertainty in LEFM ,(+ Flow and Temperature Measurements A.1 LEFM,f+Inputs A.2 LEFM,(+Uncertainty Calculations A.3 LEFM,(+ Spool Piece(s) Meter Factor and Meter Factor Uncertainty Trade A.4 [ I Secret &

Confidential A.5 [ I Commercial Information B Total Thermal Power Uncertainty B.1 Thermal Power Uncertainty Calculation using the LEFM,r+ System B.2 Thermal Power Uncertainty Calculation using the LEFM,(+ System Trade Secret &

[ I I Confidentio:

Commerci<

Information c Total Thermal Power Uncertainty C.1 Thermal Power Uncertainty Calculation [ Trade I Secret &

Confidenti<

C.2 Thermal Power Uncertainty Calculation [ Commerci:

lnformatior I

l I

Measurement Systems

1.0 INTRODUCTION

The LEFM ../ and LEFM ../ + 1 are advanced ultrasonic systems that accurately measure the volume flow and temperature of feedwater in nuclear power plants. Using a feedwater pressure signal input to the LEFM ../ and LEFM ./+ mass flow is determined. The mass flow and temperature outputs are used, along with other plant data, to compute reactor core thermal power. The technology underlying the LEFM ../ ultrasonic instruments and the factors affecting their performance are described in a topical report, Reference 1, and a supplement to this topical report, Reference 2.

The LEFM ../ +, which contains two LEFM ../ 's, is described in another supplement to the topical report, Reference 3. The exact amount of the uprate allowable under a revision to 10CFR50 Appendix K depends not only on the accuracy of the LEFM./ +outputs but also on the uncertainties in other inputs to the thermal power calculation.

It is the purpose of this document to provide an analysis of the uncertainty contribution of the Trade LEFM./ +System to the overall thermal power uncertainty at Peach Bottom Unit 3. [ Secret &

Confidential Commercial Information

] This report addresses three specific operating conditions:

[

Trade Secret &

Confidentic:

Commercic:

lnformatior The uncertainties in LEFM mass flow and feedwater temperature are used in the calculation of the thermal power uncertainty due to the LEFM ./+ (Appendix B). This appendix complies to the methodology of the Topical Report (References 1 and 2) and provides the bound for the uncertainty Trade uprate that the plant may recognize. [ Secret &

Confidentia Commercia Information

] A detailed discussion of the methodology for combining these terms is described in Reference 3.

Trade Secret &

This analysis is a bounding analysis for Peach Bottom Unit 3. [ Confidential Commercial

] Information The uncertainties in these values are bounded by this analysis.

Trade Secret &

Confidential Commercial Information ER-463NP Rev 8 Prepared by: RSH Reviewed by: BWG

Measurement Systems 2

2.0

SUMMARY

The uncertainty approach is documented in Reference 3. The Maintenance Mode uncertainty results below use the conservative plane balance term found in Appendix A.2.

1. Mass Flow Uncertainty The uncertainty in the LEFM,/'+'s system mass flow is as follows:

o All meters in Normal Mode,+/- 0.30%

0 [ ] Trade Secret &

0 [ ] Confidential Commercial 0 [ ] Information 0 [

[ Trade Secret &

Confidential Commercial

] Information

2. Temperature Uncertainty The uncertainty in the LEFM ,r+ feedwater temperature is as follows: Trade Secret &

0 [ ] Confidential Commercial 0 [ ] Information 0 [ ]

0 [ ]

0 [

3. Thermal Power Uncertainty The thermal power uncertainty approach is documented in Reference 3 and Appendix B of this document. The total uncertainty in the determination of thermal power related to the LEFM ,(+

system is as follows:

o All meters in Normal Mode,+/- 0.34%

0 [ ] Trade Secret &

0 [ ] Confidential Commercial 0 [ ] Information 0 [ ]

[

Trade Secret &

Confidentia Commercia Information ER-463NP Rev 8 Prepared by: RSH Reviewed by: BWG

Measurement Systems 3

3.0 APPROACH All errors and biases are calculated and combined according to the procedures defined in Reference 4 and Reference 5 in order to determine the 95% confidence and probability value. The approach to determine the uncertainty, consistent with determining set points, is to combine the random and bias terms by the means of the RSS approach provided that all the terms are independent, zero-centered and normally distributed.

Reference 4 defines the contributions of individual error elements through the use of sensitivity coefficients defined as follows:

A calculated variable Pis determined by algorithm f, from measured variables X, Y, and Z.

P = f(X, Y, Z)

The error, or uncertainty in P, dP, is given by:

dP =g_I dx+

af l7 qi qi O'Y XZ dY+

iJZ XY dz As noted above, Pis the determined variable--in this case, reactor power or mass flow-- which is calculated via measured variables X, Y, and Z using an algorithm f (X, Y, Z). The uncertainty or error in P, dP, is determined on a per unit basis as follows:

dP ={x P

g_I Pa\' 17

}dx X

+{r qi PO'Y xz

}dr Y

+{z qi POZxr

}dz Z

where the terms in brackets are referred to as the sensitivity coefficients.

If the errors or biases in individual elements (dXIX. dYIY, and dZIZ in the above equation) are all caused by a common (systematic) boundary condition (for example a common instrument) the total error dP/ P is found by summing the three terms in the above equation. If, as is more often the case, the errors in X, Y, and Z are independent of each other, then Reference 4 recommends and probability theory requires that the total uncertainty be determined by the root sum square as follows (for 95% confidence and probability):

Obviously, if some errors in individual elements are caused by a combination of boundary conditions, some independent and some related (i.e., systematic) then a combination of the two procedures is appropriate.

ER-463NP Rev 8 Prepared by: RSH Reviewed by: BWG

Measurement Systems 4

4.0 OVERVIEW The analyses that support the calculation of LEFM ,/+uncertainties are contained in the appendices to this document. The functions of each appendix are outlined below.

Appendix A.1, LEFM,/+Inputs This appendix tabulates dimensional and other inputs to the LEFM ,/ + which is used for the computation of mass flow and temperature. [ Trade Secret&

Confidential

] are used in this appendix. Commercial Information Appendix A.2, LEFM,/+Uncertainty Calculations This appendix calculates the uncertainties in mass flow and temperature as computed by the LEFM ,/ + using the methodology described in Appendix E of Reference 1 and Appendix A of Reference 33 , with uncertainties in the elements of these measurements bounded as described in both references 4 . The spreadsheet calculation draws on the data of Appendix A. I for dimensional information. [

Trade Secret &

Confidential Commercial Information This appendix utilizes the results of the calibration testing for the plant spool piece(s) for the uncertainty in the profile factor (calibration coefficient). The engineering reports for the spool piece calibration tests are referenced in Appendix A.3 to this report.

Appendix A.3, Meter Factor and Meter Factor Uncertainty The calibration test report for the spool piece(s) establishes the overall uncertainty in the meter (profile) factor of the LEFM ,/ +. The elements of the meter factor uncertainty include

[ Trade Secret &

Confidentia Commercia

] are also Information elements in establishing the uncertainty in meter factor.

Trade Secret &

Confidential Commercial Information 3

Reference 3 (ER 157P) develops the uncertainties for the LEFM ./+ system. Because this system uses two measurement planes, the structure of its uncertainties differs somewhat that of an LEFM ./.

4 Reference 3 (ER 157P) revised some of the time measurement uncertainty bounds. The revised bounds are a conservative projection of actual performance of the LEFM hardware. ER SOP used bounds that were based on a conservative projection of theoretical performance.

ER-463NP Rev 8 Prepared by: RSH Reviewed by: BWG

Measurement Systems 5

]

[ Trade Secret &

Confidentia Commercia lnfonnation

]

[

]

[

Appendix A.4, [

Trade Secret &

Confidential

] Commercial lnfonnation Appendix A.5, (

Trade Secret &

Confidential Commercial lnfonnation Appendix B, Total Thermal Power Uncertainty using the LEFM ./+

The total thermal power uncertainty for a plant using the LEFM ./+ system is calculated in this appendix. It combines the results provided in Appendix A, along with plant specific terms (ex., steam enthalpy, moisture carryover, etc.).

These terms have been combined in a method consistent with that described in the Topical Report and its supplements (References 1, 2, and 3). Appendix B reconciles the results of this analysis with ERi 57(P-A) Rev. 8 (Reference 3).

Appendix C, Total Thermal Power Uncertainty [

]

Trade Appendix C has a special calculation for Peach Bottom [ Secret &

] Confidential Commercial lnfonnation ER-463 NP Rev 8 Prepared by: RSH Reviewed by: BWG

Measurement Systems 6

5.0 REFERENCES

1) Cameron Topical Report ER-80P, "Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM Check System, dated March 1997, Revision 0

2) Cameron Engineering Report ER-160P, "Supplement to Topical Report ER 80P: Basis for a Power Uprate with the LEFM System, dated May 2000, Revision 0

3) Cameron Engineering Report ER-157(P-A), "Supplement to Caldon Topical Report ER-80P: Basis for Power Uprates with an LEFM Check or an LEFM CheckPlus, dated May 2008, Revision 8

4) ASME PTC 19.1, Measurement Uncertainty

5) Caldon Engineering Report ER-590, "The Effects of Random and Coherent Noise on LEFM CheckPlus Systems", Rev. 2 ER-463NP Rev 8 Prepared by: RSH Reviewed by: BWG

Measurement Systems Appendix A Appendix A.1, LEFM./+ Inputs Appendix A.2, LEFM ./+ Uncertainty Calculations Appendix A.3, LEFM./+ Spool Piece(s) Meter Factor and Meter Factor Uncertainty Trade Appendix A.4, I Secret &

Confidential Commercial Appendix A.S, I Information Schlumberger-Private

Measurement Systems Appendix A.1 LEFM ./+ Inputs No Attachment to follow, as Appendix is Proprietary in its Entirety

Measurement Systems Appendix A.2 LEFM ./+ Uncertainty Calculations No Attachment to follow, as Appendix is Proprietary in its Entirety

Measurement Systems Appendix A.3 LEFM,.I'+Spool Piece(s) Profile Factor and Profile Factor Uncertainty Reference Caldon Engineering Reports ER-375 Rev 1, "Profile Factor Calculation and Accuracy Assessment for the Peach Bottom Unit 3 Replacement LEFM v" + Spool Pieces, August 2016

Measurement Systems Appendix A.4 Trade Secret &

I Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety

Measurement Systems Appendix A.5 Trade Secret &

I Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety

Measurement Systems Appendix B-1 Thermal Power Uncertainty Calculation using the LEFM./+System No Attachment to follow, as Appendix is Proprietary in its Entirety

Measurement Systems Appendix B-2 Thermal Power Uncertainty Calculation using the LEFM ./+ System Trade

[ ] Secret &

Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety

Measurement Systems Appendix C-1 Trade Thermal Power Uncertainty Calculation [ Secret &

Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety

Measurement Systems Appendix C-2 Thermal Power Uncertainty Calculation [ Trade Secret &

Confidential Commercial Information No Attachment to follow, as Appendix is Proprietary in its Entirety

Valves & Measurement Sales HEADQUARTERS +1 .281.582.9500 measurement@c-a-m.com (HOUSTON, TX. USA)

Service CANADA +1 .403.291.4814 MIDDLE EAST & NORTH AFRICA +971 .4802.7700 ms-services@c-a-m.com LATIN AMERICA +54.11.5070.0266 EUROPE, CASPIAN, RUSSIA +44.1892.518000 INDIA +91.9903822044 & SOUTH AFRICA ASIA PACIFIC +603.7954.0145 www.cameron.slb.com Schlumberger-Private

v t e Letter Sequence Request
EPID:L-2018-LLA-0230, License Amendment Request - Expanded Actions for LEFM Conditions (Approved, Closed)
Initiation Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2018-09-10 [Table View]

ML18239A355

Text

Subject:

Reference:

SUMMARY

3.0 TECHNICAL EVALUATION

5.0 REGULATORY EVALUATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

5.0 REGULATORY EVALUATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

REFERENCES:

REFERENCES:

Title:

4.0 REFERENCES

8.0 CONCLUSION

4.0 REFERENCES

8.0 CONCLUSION

Subject:

Subject:

Subject:

Subject:

Subject:

Subject:

Subject:

Dear Mr. Kaczmorski,

Subject:

Subject:

1.0 INTRODUCTION

SUMMARY

5.0 REFERENCES

1.0 INTRODUCTION

SUMMARY

5.0 REFERENCES

1.0 INTRODUCTION

SUMMARY

5.0 REFERENCES

1.0 INTRODUCTION

SUMMARY

5.0 REFERENCES

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