GNRO-2012/00132, License Amendment Request for Revision of Technical Specification Allowable Value for Primary Containment and Drywell Isolation Instrumentation Function 3.c RCIC Steam Supply Line Pressure - Low.

License Amendment Request for Revision of Technical Specification Allowable Value for Primary Containment and Drywell Isolation Instrumentation Function 3.c RCIC Steam Supply Line Pressure - Low.

ML12318A119
Person / Time
Site:	Grand Gulf
Issue date:	11/09/2012
From:	Mike Perito Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
GNRO-2012/00132
Download: ML12318A119 (128)

Text

.-

~Entergy Entergy Operations, Inc.

P. o. Box 756 Port Gibson, MS 39150 Michael Perito Vice President, Operations Grand Gulf Nuclear Station Tel. (601) 437-6409 GNRO-2012/00132 November 9, 2012 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

License Amendment Request for Revision of Technical Specification Allowable Value for Primary Containment and Drywell Isolation Instrumentation Function 3.c "RCIC Steam Supply Line Pressure - Low."

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCE:

NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety" dated December 29, 1989

Dear Sir or Madam:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Operations, Inc. is submitting a request for an amendment to the Technical Specifications (TS) for Grand Gulf Nuclear Station, Unit 1 (GGNS). The proposed amendment would revise the TS to support correction of a non-conservative technical specification allowable value.

• Attachment 1 provides an evaluation of the proposed changes.

• Attachment 2 provides the markup pages of existing TS to show the Proposed changes.

• Attachment 3 provides revised (clean) TS pages.

• Attachment 4 provides calculation Je-Q1E31-N685..1 "RCIC Turbine Isolation on Low Inlet Steam Pressure"

• Attachment 5 provides JS09 Revision 1 "Grand Gulf Nuclear Station Instrument and Control Standard Methodology For The Generation Of Instrument Loop Uncertainty &

Setpoint Calculations" Entergy Operations, Inc. requests approval of the proposed license amendment by November 9, 2013 with the amendment being implemented within 90 days.

GNRO-2012100132 Page 2 of3 In accordance with 10 CFR 50.91 (a)(1). "Notice for Public Comment," the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission in accordance with the distribution requirements in 10 CFR 50.4. In accordance with 10 CFR 50.91 (b)(1). "State Consultation." a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated Mississippi Official.

This letter contains no new commitments.

If you have any questions or require additional information. please contact Jeffery A.

Seiter at 601-437-2344.

I declare under Penalty of Perjury that the foregoing is true and correct. Executed on November 9. 2012.

MP/jas Attachments:

1. Evaluation of Proposed Changes

2. Proposed Technical SPeCification Changes (Mark-up)

3. Revised Technical SPeCification Changes (Clean Copy)

4. Calculation Je-C1E31-N685-1 "RCIC Turbine Isolation on Low Inlet Steam Pressure" 5 JS09 Revision 1 "Grand Gulf Nuclear Station Instrument and Control Standard Methodology For The Generation Of Instrument Loop Uncertainty & Setpoint Calculations" cc: (see next page)

GNRO-2012/00132 Page 3 of 3 cc: Mr. John Boska, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555 Mr. Elmo E. Collins, Jr.

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 1600 East Lam ar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission ATTN: Mr. A. Wang, NRRlDORL Mail Stop OWFN/8 G14 11555 Rockv iIIe Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Mr. Nathaniel Ferrier, NRRlDORL Mail Stop OWFN/ 11 F 1 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 Dr. Mary Currier, M.D., M.P.H State Health Officer Mississippi Department of Health P. O. Box 1700 Jackson, MS 39215-1700

Attachment 1 GNRO*2012/00132 Evaluation of Proposed Changes

GNRO-2012/00132 Page 1 of6 1.0

SUMMARY

DESCRIPTION This letter is a request to the Nuclear Regulatory Commission (NRC) to amend Facility Operating License NPF-29 for the Grand Gulf Nuclear Station (GGNS). The requested change affects Technical Specification (TS) Table 3.3.6.1-1 Allowable Value for Primary Containment and Drywellisolation Instrumentation Function 3.c "Reactor Core Isolation Cooling (RCIC) Steam Supply Line Pressure - Low". This request is submitted pursuant to 10 CFR 50.90 to correct a non conservative TS and, consistent with the guidance of NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety", dated December 29,1989 (reference 6.1).

TS Allowable Value for Primary Containment and Drywell Isolation Instrumentation Function 3.c "RCIC Steam Supply Line Pressure - Low" is changed from greater than or equal to (~) 53 psig to greater than or equal to (~) 57 psig.

As demonstrated in this submittal, the proposed change does not adversely impact safety and is required by NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety". Entergy Operations, Inc.

requests approval of the proposed license amendment by November 9, 2013. Once approved, Entergy will implement the amendment within 90 days.

2.0 DETAILED DESCRIPTION 2.1 Proposed Changes A recent revision of Calculation JC-Q1 E31-N685-1 "RCIC Turbine Isolation on Low Inlet Steam Pressure" (reference 6.4) updated the methodology and assumptions used in the calculation. This revision resulted in a new calculated allowable value of

~ 56.21 psig versus the current allowable value of ~ 53 psig. The current setpoint of 60 psig as delineated in Function 3. of RCIC System Isolation in Technical Requirement Manual (TRM) Table 3.3.6.1-1 "Technical Specification Isolation Instrumentation Trip Setpoints and Response Times" remains conservative with a calculated setpoint of 56.73 psig. The non-conservative allowable value is required to be revised in accordance with NRC Administrative Letter 98-10.

2.2 Need for Changes The discovery of a non-conservative allowable value requires a change to technical specifications. This change is required to ensure that the TS is sufficient to assure nuclear safety.

2.3 TSTF*493 Considerations GGNS is aware of the NRC position to encourage TSTF-493 (Reference 6.3) adoption by requiring licensees to provide a determination for each instrumentation function proposed for revision, as to whether the function is a Limiting Safety System Setting (LSSS) that protects a safety limit. A review of the TSTF-493 traveler for this particular instrument function indicates that this function is not an LSSS that protects a safety limit. Attachment A to TSTF-493, Revision 4, entitled "Identification of Functions to be Annotated with TSTF-493 Footnotes,"

identifies those functions that are LSSS. Under the Attachment A listing for

GNRO-2012/00132 Page 2 of6 NUREG-1434, "Boiling Water Reactor/6 Plants", Technical Specification Table 3.3.6.1-1 "Allowable Value for Primary Containment and Drywell Isolation Instrumentation" Function 3.c "Reactor Core Isolation Cooling (RCIC) Steam Supply Line Pressure - Low" is not listed as a LSSS. Since this function is not a LSSS no change to the TS is required with respect to this function.

3.0 TECHNICAL EVALUATION

3.1 RIS*2005*20 Revision 1 In NRC GL 91-18 and superseded by RIS-2005-20 Revision 1(reference 6.2), the NRC provided guidance for prompt corrective action to correct or resolve a degraded or non-conforming condition. In the case of non-conservative TS, this includes the evaluation of compensatory measures, such as administrative controls, in accordance with 10 CFR 50.59 and prompt actions to correct the TS. This section provides a description of the methodology used by Entergy to complete the evaluation for the requested TS allowable value change.

GGNS utilizes the methodology documented in JS-09 Rev. 1 "Methodology for the Generation of Instrument Loop Uncertainty & Setpoint Calculations." (reference 6.5) to calculate loop uncertainties and setpoints. This methodology is used coincident with the GE instrument setpoint methodology published in NEDC-31336. This method includes using the available uncertainty data along with the following general steps to generate an appropriate loop Allowable Value and Nominal Trip Setpoint.

• Calculate the Loop Uncertainty (LU) by computing the SRSS of the Loop Device Uncertainty (Ad, the Loop Calibration Uncertainty (Cd, the Process Measurement Uncertainty (PM), and the Primary Element Uncertainty (PE).

• Calculate the Loop Drift (Dd by computing the SRSS of the Device Drift (DR), the Temperature Drift (TD), and the Radiation Drift (RD) for each loop instrument as applicable.

• Calculate the Total Loop Uncertainty (TLU) by summing the Loop Uncertainty, the Loop Drift and any applicable biases.

• For process variables that increase to the Analytical Limit (AL), calculate the loop Allowable Value (AV) by subtracting the Loop Uncertainty from the Analytical Limit. For process variables that decrease to the Analytical Limit, calculate the loop Allowable Value by summing the value of the Loop Uncertainty and the Analytical Limit.

• For process variables that increase to the Analytical Limit (AL), calculate the loop Nominal Trip Setpoint (NTSP) by subtracting the value of the Total Loop Uncertainty from the Analytical Limit. For process variables that decrease to the Analytical Limit, calculate the loop Nominal Trip Setpoint (NTSP) by summing the value of the Total Loop Uncertainty and the Analytical Limit.

Calculation JC-Q1 E31-N685-1 "RCIC Turbine Isolation on Low Inlet Steam Pressure" (reference 6.4 and found in attachment 4) determines the instrument loop uncertainty, limiting allowable values and setpoints for instrument loops to isolate the RCIC Turbine on low inlet steam pressure to protect the turbine. The revision to the calculation did not result in a setpoint change, only the allowable value was required to be changed. The functionality of the associated instrumentation for the RCIC

GNRO-2012/00132 Page 3 of6 Turbine Isolation on Low Inlet Steam Pressure setpoint are not in question since the actual plant setpoints are currently conservative with respect to the analytical limits.

Therefore, the instrumentation can perform its specified TS safety function.

The TRM trip setpoint is not changed; therefore the system remains capable of performing its specified safety function in accordance with applicable design requirements and associated analyses. Since the system remains capable of performing its specified safety function, no compensatory measures are required.

The condition report documenting the non-conservative technical specification is screened as operable degraded nonconforming (DNC) as required by GL-91-18 and this license application request (LAR) is submitted to request permission to revise technical specifications to eliminate the non-conservative allowable value.

4.0 REGULATORY SAFETY ANALYSIS NRC GL 91-18 provides generic guidance to licensees on the type and time frame of any required corrective action for resolution of degraded and nonconforming conditions. As stated in the GL, whenever degraded or nonconforming conditions are discovered, 10 CFR Part 50, Appendix B, requires prompt corrective action to correct or resolve the condition. In the case of a deficient TS, this includes the evaluation of compensatory measures, such as administrative controls, in accordance with 10 CFR 50.59 and prompt actions to correct the TS. This request for license amendment provides the GGNS-specific actions to resolve the degraded or nonconforming condition. GGNS has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any draft General Design Criteria differently than described in the GGNS UFSAR, as described below.

4.1 Applicable Regulatory Requirements/Criteria Regulatory requirement 10 CFR 50.36, "Technical Specifications," provides the content required in a licensee's TS. Specifically, 10 CFR 50.36(c)(3) requires that the TS include surveillance requirements. The proposed TS allowable value (AV) change continues to support the requirements of 10 CFR 50.36(c)(3) to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation are met.

Calculation JC-Q1 E31-N685-1 "RCIC Turbine Isolation on Low Inlet Steam Pressure" determines the instrument loop uncertainty, limiting allowable values and setpoints for instrument loops to isolate the RCIC Turbine on low inlet steam pressure to protect the turbine. This calculation documents the methodology and assumptions used for the calculation. The revision to the calculation did not result in a setpoint change; only the allowable value was required to be changed. This request for license amendment provides the GGNS specific calculation used to determine the setpoint and allowable value evaluation and provides a description of the methodology used by GGNS to complete the evaluation for the specific TS SR being revised.

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

GNRO-2012/00132 Page 4 of6 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.2 No Significant Hazards Consideration 10 CFR 50.91 (a)(1) requires that licensee requests for operating license amendments be accompanied by an evaluation of no significant hazard posed by issuance of the amendment. Entergy has evaluated this proposed amendment with respect to the criteria given in 10 CFR 50.92(c). The following is the evaluation required by 10 CFR 50.91 (a)(1).

Entergy is requesting an amendment of the Operating License for the Grand Gulf Nuclear Station (GGNS) to revise the Technical Specification (TS) Allowable Value (AV) for Primary Containment and Drywellisolation Instrumentation Function 3.c "RCIC Steam Supply Line Pressure - Low".

Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on 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?

Response: No.

The proposed TS allowable value change involves a change in the margin between the allowable value and the setpoint. The proposed TS change does not change the trip setpoint. The proposed TS change does not degrade the performance of, or increase the challenges to, any safety systems assumed to function in the accident analysis. The proposed TS change does not impact the usefulness of the SRs in evaluating the operability of required systems and components, or the way in which the surveillances are performed. In addition, the the trip setpoint for the associated TRM function is not considered an initiator of any analyzed accident, nor does a revision to the allowable value introduce any accident initiators. Therefore, the proposed change does not involve a significant increase in the probability of an accident previously evaluated.

The consequences of a previously evaluated accident are not significantly increased. The proposed change does not affect the performance of any equipment credited to mitigate the radiological consequences of an accident.

Evaluation of the proposed TS changes demonstrated that the availability of credited equipment is not significantly affected because of the reduction in margin between the allowable value and the trip setpoint.

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

GNRO-2012/00132 Page 50f6

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 TS change involves a change in the allowable value setting to correct a non-conservative value. The proposed TS change does not introduce any failure mechanisms of a different type than those previously evaluated, since there are no physical changes being made to the facility.

No new or different equipment is being installed. No installed equipment is being operated in a different manner. As a result, no new failure modes are being introduced. The way surveillance tests are performed remains unchanged.

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

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No.

The proposed TS change involves a change in the allowable value setting to correct a non-conservative value. The impact of the change on system availability is not significant, based on the frequency of the testing being unchanged, the existence of redundant systems and equipment, and overall system reliability. The proposed change does not significantly impact the condition or performance of structures, systems, and components relied upon for accident mitigation. The proposed change does not result in any hardware changes or in any changes to the analytical limits assumed in accident analyses. Existing operating margin between plant conditions and actual plant setpoints is not significantly reduced due to these changes. The proposed change does not impact any safety analysis assumptions or results.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the responses to the above questions, GGNS concludes that the proposed amendment with respect to the TS AV change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusion 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 to the health and safety of the public.

GNRO-2012/00132 Page 6 of6

5.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

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

6.0 REFERENCES

6.1 NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety" dated December 29, 1989 6.2 RIS-2005-20 Revision 1, Revision to NRC Inspection Manual Part 9900 Technical Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety" Dated April 16, 2008 6.3 Technical Specification Taskforce Traveler Improved Standard Technical Specifications Change Traveler, TSTF - 493, Revision 4, "Clarify Application of Setpoint Methodology for LSSS Functions.

6.4 Calculation JC-Q1 E31-N685-1 "RCIC Turbine Isolation on Low Inlet Steam Pressure" 6.5 JS-09 Rev. 1 "Methodology for the Generation of Instrument Loop Uncertainty &

Setpoint Calculations."

Attachment 2 GNRO-2012/00132 Proposed Technical Specification Changes (Mark-up)

Primary Conta; nment and Orywell Isolati on Instrumentation 3.3.6.1 Tabl~ 3.3.6.1-1 (page 3 of 5)

Primary COl1tilil'lmentand Dryw~11 Isolation Iflstrl!lJ\et1~ation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECLFI ED CHA.N;NELSPER REQUIRED SURVEILLANCE ALLOWABLE FUNcnON CONDITIONS TRIP SYSTEM ACTION C.l REQUIREMENTS VALUE

3. Reactor Core Isolation Cooling (RCIe) System Isolation

a. RCIC Steam Line l,Z.3 SR 3.3.6.1.1 s64 inches F'low-lii9tl SR3.3 .6.1. 2 water SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7

b. RC 1C Steam Line Flow 1,2,3 1 f SR 3.3.6.1.2 ~ 3 second.S and ~

Time Oel ay SI( 3,3.6:.1.4 SR 3.3.6.1.7 S7~~

c. RCIC Steam. Supply L ina F SR 3.3.6.1.1 a~ psig I P*tessure-Lolll SR 3.3.6 ..1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3,3.6*.1.J

d. RCIC TUrbine Exhaust I,Z.3 F SR 3.3.6.1.1 $ 20 psig Oiaphragm SR 3.3.6.1.2 Pressure-High SR h3.6.1.3 5R 3.3.6 . 1. 6 SR 3.3.6.1.7

e. Rete EquiPment Room 1.2,3 F SR 3.3.6. L 1 s 191°F Ambient SR 3.3.6.1.2 Temperature - High SR 3.3.6.1.5 SR 3.3.6.1. 7

f. Main Stealll Line Tunl1el 1,2,3 SR 3.3.6.1.1 ~ 191°F Ambient SR 3.3 .* 6.1.2 Temperature - Hi gh SR 3.3.6.1,5 SR 3.3.6.1. 7

g. Main Steam Line Tunnel F SR 3.:L6.l.2 S 30 minutes Temperature Ttmer SR 3.3.6 .1. 4 SR 3.3.6.1. 7

h. RHR Equj pment Room 1.Z*,3 1 pertQOIll F SR 3.3.6.1.1 S 1710 F Ambient SR 3.3.6.1.2 Temperature-High SR 3.3.6.1.5 SR 3.3.6.1.7

i. RClCIRHR Steam Line F SR 3.3.6.1. 1 s 43 illcheS Floli

• High SR 3.3.6.1.2 water SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.1

( continued).

(dJNot r~qulred to be OPERABLE fn MODE 2: or 3 with reactor steam dome pressure less than 150 psf.g during reactor startup.

GRANO GULF 3 .. 3*56 Amendment No. .~ I -::1:::6t-

Attachment 3 GNRO*2012/00132 Revised Technical Specification Changes (Clean Copy)

Primary Containment and Drywell Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 3 of 5)

Primary Containment and Drywell Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS RE~UIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS PER TRIP ACT ONC.l REQUIREMENTS VALUE SYSTEM

3. Reactor Core Isolation Cooling (RCIC) System Isolation

a. RCIC Steam Line 1,2,3 F SR 3.3.6.1.1 ~ 64 inches Flow c High SR 3.3.6.1.2 water SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7

b. RCIC Steam Line Flow 1,2,3 F SR 3.3.6.1.2 ~ 3 seconds and Time Delay SR 3.3.6.1.4 ~ 7 seconds SR 3.3.6.1.7

c. RCIC Steam SU~ly l,id),3(d) F SR 3.3.6.1.1 ~ 57 psig Line Pressure C ow SR 3.3.6.1.2 SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7

d. RCIC Turbine Exhaust 1,2,3 2 F SR 3.3.6.1.1 ~ 20 psig D~hragm Pressure SR 3.3.6.1.2 C Igh SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7

e. RCIC Equipment Room 1,2,3 F SR 3.3.6.1.1 ~ 191EF Ambient SR 3.3.6.1.2 Temperature C High SR 3.3.6.1.5 SR 3.3.6.1.7

f. Main Steam Line 1,2,3 F SR 3.3.6.1.1 ~ 191EF Tunnel Ambient SR 3.3.6.1.2 Temperature C High SR 3.3.6.1.5 SR 3.3.6.1.7

g. Main Steam Line 1,2,3 F SR 3.3.6.1.2 ~ 30 minutes Tunnel Temperature SR 3.3.6.1.4 Timer SR 3.3.6.1.7

h. RHR Equipment Room 1,2,3 1 per room F SR 3.3.6.1.1 ~ 171EF Ambient SR 3.3.6.1.2 Temperature C High SR 3.3.6.1.5 SR 3.3.6.1.7

i. RCIC/RHR Steam Line 1,2,3 F SR 3.3.6.1.1 ~ 43 inches Flow-High SR 3.3.6.1.2 water SR 3.3.6.1.3 SR 3.3.6.1.6 SR 3.3.6.1.7 (continued)

(d) Not required to be OPERABLE in MODE 2 or 3 with reactor steam dome pressure less than 150 psig during reactor startup.

GRAND GULF 3.3-56 Amendment No. ~, ~

Attachment 4 GNRO*2012/00132 Calculation JC*Q1E31*N685-1 "RCIC Turbine Isolation on Low Inlet Steam Pressure"

bJ ANQ.l bJ ANQ-2 ~GGNS OlP.2 DIP.3 DpLP DlAF o NP-GONS-3 DPNPS ONP-RBS-3 ORBS Ow OW)

CALCULATION 39554 COVE R PAGE '1'1 EC# {:lTage 1 of H

I (3) Design Basis Calc. lZJ YES DNO f (4) o CALCULATION ~ECMarkup (S) Caleul ation No: JC-Q] E31-N685.. t (6) Revision: 001 (7)

Title:

Instrument Loop Uncertainty and Setpoint Dctennination for System (I) Editor ial E31 u>op N685 RCIC Turbine Isolation on Low Inlet Steam Pressure DYES ~NO (9) System (s): E31 (fiij--Review Org (Depar tment) : NPE (I&C Design)

(II) Safety Class:

(J:l) COlllp onentl Eqaipm eDtlSt rudure TypeIN umber :

cg] Safety I Qualit y Relate d Io0 Augmented Qualit y Progra m Non-Safety Related 1E31 N085A,B IE31N685A..B (U'Document Type: J05.02 (14) Keywo rds (Deser iptiont ropiea l Codes): setpoin~ uncertainty. ReTe, turbine REVIE WS

(' ~E ar e (I6 )~D ate (17) Name/Signature/Date

~ W. flu,.~ ll/"/(z" 11('-/~/2.

See associated Ee Ro n mith I See associated EC II"/ I'z" TNO""AA W. THOQ. .tJTotv I See associated EC I Responsible Engin eer [81 Design Verifier o Reviewer SupervisorlAppro val 181 Comments Attached o Comments Attached

~ ENTERGY s> --

CALCULATION NO.

$?

(. "

./

,,~:-, CALCULATION SHEET JC-OIE31-N685-1 SHEET 2 REV.

OF 1

41 Revision Record of Revision 0 Original Issue EC-39554. Revised to incorporate GEXI2000-00 134, GIN 96-02302, updated references and referenced infonnation, calculated PM error in section 5.11.1.

1 Revised and refonnatted calculation to meet current requirements of JS09.

Incorporated 24 month drift per JC-Q 1111-090 19. Added computation of ALT and AFT per TSTF-493.

~ENTERGY s£ r.. . ,

.~ CALCULATION SHEET SHEET 3 OF 41 CALCULATION NO. JC-Q I E31-N685-1 REV. I CALCULATION CALCULATION NO: JC-QIE31-N685-1 Rev I REFERENCE SHEET

1. EC MARKUPs INCORPORATED (N/A to NP calculations): None II Relationships: Sht Rev Input Output Impact Tracking No.

Doc Doc YIN

l. JS09 0 001 ..-

rtJ 0 N

2. JI250L 024A 001 0 0 N

3. JI250L 024B 001 Ii'J 0 N

4. 06-IC-I E31-0-1016 - 107 Ii'J 0 N

5. MI090A 0 019 Ii'J 0 N

6. 22A3124 0 005 Ii'J 0 N

7. 22A3735AA 0 004 Ii'J 0 N

8. GIN96-02302 - 0 Ii'J 0 N

9. GEXI2000-00134 - 0 ~ 0 N

10. 460000047 0 300 ~ 0 N II. 460002635 0 300 ~ 0 N

12. PERR91-6068 - 001 ~ 0 N

13. AOOl2 0 015 ~ 0 N

14. 184C4571 001 009 ~ 0 N

15. 164C5150 001 018 ~ 0 N

16. 169C8394 002 008 ~ 0 N

17. 865E517 002 014 ~ 0 N

18. NEDC31336 - 0 Ii'J 0 N

19. EI00.0 0 007 ~ 0 N

20. 865E516 002 008 Ii'J 0 N

21. 368X543BA 0 044 ~ 0 N

22. 368X551BA 0 021 Ii'J 0 N

23. FSK-I-9999-249-C - 006 Ii'J 0 N

24. FSK-S-1090A-082-C 0 009 Ii'J 0 N

25. FSK-I-9999-152-C - 009 Ii'J 0 N

26. FSK-S-1090A-016-C 0 013 Ii'J 0 N

27. FSK-S-I090A-017-C 0 015 ~ 0 N 28.06-IC-IE31-R-IOI6 - 103 Ii'J 0 N

29. JC-QIIII-09019 0 000 Ii'J 0 N

30. GGNS-NE-11-00011 0 000 Ii'J 0 N

-=- ENTERGY CALCULATION NO.

~_\_:~,

"-/ \ -

CALCULATION SHEET JC-OIE31-N685-1 SHEET 4 OF REV. 1 41 II Relationships: Sht Rev Input Output Impact Tracking No.

Doc Doc YIN

31. J1507A 0 001 ~ 0 N

32. J0400 0 018 ~ 0 N

33. J0401 0 014 ~ 0 N

34. A0120 0 016 ~ 0 N

35. AOOl4 0 009 ~ 0 N

36. QP0399 - 013 0 0 N

37. 460003606 0 300 ~ 0 N Ill. CROSS

REFERENCES:

1. Asset Suite Equipment Data Base (EDB)

2. UFSAR, Section 5.4.6

3. Technical Specifications, Table 3.3.6.1-1

4. Technical Specifications, Table TR3.3.6.1-1

5. "Flow Measurement Engineering Handbook" by R.W.Miller, published by McGraw-Hill Book Company, 1983

6. ASME Steam Tables, Sixth Edition IV. SOFTWARE USED:

Title:

N/A VersioniRelease: Disk/CD No.

V. DISK/CDS INCLUDED:

Title:

N/A Version/Release Disk/CD No.

VI. OTHER CHANGES:

Related references removed from the calculation:

EDP 32, ES-19, 368X533, API 90/1253, EAR E900158, 06-IC-IE31-R-0023, 460000944

CALCULATION SHEET SHEET 5 OF _4,;.-,1_

CALCULATION NO. JC-OIE31-N685-1 REV. 1_ _

TABLE OF CONTENTS SHEET SECTION 1.0 PURPOSE 6 2.0 DESIGN REQUIREMENTS 6

3.0 REFERENCES

7 4.0 GIVEN 9 5.0 ASSUMPTIONS 14 6.0 METHODOLOGY 19 7.0 CALCULATION 21

8.0 CONCLUSION

27 ATTACHMENTS Design Verification (5 sheets) 2 Owner's Review Comments (6 sheets)

CALCULATION SHEET SHEET 6 OF 41 CALCULATION NO. JC-OIE3I-N685-1 REV._-=--_ _

1.0 PURPOSE The purpose of this calculation is to detennine the instrument loop uncertainties, limiting allowable values and setpoints for instrument loops IE3I-N685A & B. The values generated by this calculation are in accordance with reference 3.1.1.

2.0 DESIGN REQUIREMENTS Design Basis Description The RCIC system is provided to assure adequate core cooling in the event of reactor isolation from its primary heat sink and the loss of feedwater flow to the reactor vessel without requiring actuation of any of the Emergency Core Cooling System equipment (Ref.

3.1.28).

The RCIC turbine is tripped and isolated from its steam supply when the supply pressure drops below that required for safe operation. 1E31-PT-N085 monitors the pressure in the RCIC steam supply line just downstream of its tap off the Main Steam Line and, through trip switch 1E3I-PIS-N685, furnishes a trip signal on decreasing pressure to the RCIC steam isolation valve trip logic (Ref. 3.1.30, 3.1.28).

Design Basis Event (DBE)

Since the RCIC turbine is not required for any design basis accidents, the initiating event for RCIC steam supply isolation is low reactor steam pressure in the event of reactor isolation from its primary heat sink and the loss of feedwater flow to the reactor vessel. This event would cause the suppression pool to heat up, but would not change any of the environmental conditions in the drywell or the containment. Therefore, these instruments do not have to operate during accident conditions.

These instruments are classified as QFl (Ref. 3.2.3). Therefore, this equipment is required to operate under SSE (Safe Shutdown Earthquake) conditions. However per Reference 3.1.1, seismic effects are not required to be considered for setpoint loops.

Therefore seismic effects will not be considered for the subject loops.

Reference 3.1.32 identifies the design limit (AL) for the RCIC turbine low steam pressure as 50 psig. The Technical Specification Allowable Value (AV) is 2: 53 psig (Ref. 3.2.1). The Technical Specification nominal trip setpoint (NTSP) is 2: 60 psig (Ref. 3.2.2).

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CALCULATION NO. JC-OIE31-N685-1

3.0 REFERENCES

3.1 Relationships 3.l.1 JS09, Instrumentation & Control Standard Safety Related Methodology For The Generation Of Instrument Loop Uncertainty & Setpoint Calculation 3.1.2 Loop Diagrams J 1250L-024A J1250L-024B 3.1.3 GIN96-02302, Calculation Change Due To Replacement Of Power Supply By ER96-0514 Revision 0 3.1.4 M 1090A, Piping & Instrumentation Diagram Leak Detection System 3.1.5 GEXI2000-00134, Statistical Variation Associated With Published Performance Variable 3.1.6 460003606, "Fluke" Fluke 45 Dual Display Digital Multimeter 3.1.7 NEDC31336, General Electric Instrument Setpoint Methodology 3.1.8 06-IC-IE31-R-I016, RCIC Steam Supply Low Pressure Calibration 3.1.9 460002635, "GE" Operations & Maintenance Instructions For Analog Trip System Qualified To IEEE 323-1971 3.1.1 0 460000047, Rosemount Inc. Trip/Calibration System 3.1.11 EI00.0, Technical Specification For Environmental Safety Related Parameter 3.1.12 169C8394-002, Gage Pressure Transmitter 3.1.13 06-IC-IE31-Q-I016, RCIC Steam Supply Low Pressure Functional Test 3.1.14 368X543BA,ReactorVessel & Level & Pressure Local Panel A 3.1.15 368X551BA, Main Steam Flow Local Panel A 3.1.16 865E516-002, Division 2 Residual Heat Removal Relay VB 3.1.17 865E517-002, Division 1 Low Pressure Core Spray & Residual Heat Removal Relay VB 3.1.18 164C5150-001, Purchased Part Trip Unit 3.1.19 184C4571-00 I, Purchased Part Power Supply 3.1.20 FSK-I-9999-249-C, lE31-PDT-N084 lE31-PT-N085A Instrument Tubing Run 3.1.21 FSK-S-I090A-082-C, DCB-27 St Fr DBA-24 Elb Ftg To PDTN084A

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3.1.22 FSK-S-I090A-017-C, DCB-27 St Fe DBA-24 Elbow Ftg To Lek Detection Sys 3.1.23 FSK-I-9999-152-C, Instrument Tubing Runs PanellH22-POl5 3.1.24 FSK-S-I090A-016-C, DCB-27 St Fe DBA-24 Elbow Ftg To Leak Detection Sys 3.1.25 QP0399, Panel 1H22P004 3.1.26 AOO 14, General Floor Plan Floor Plan At Elevation 185 & 189 Feet 3.1.27 AOOI2, General Floor Plan Floor Plan At Elevation 133 Feet 136 Feet 139 Feet 144 Feet & 148 Feet 3.1.28 22A3124, Reactor Core Isolation Cooling System 3.1.29 PERR91-6068, Rosemount 710DU 3.1.30 22A3735AA, Leak Detection System 3.1.31 JC-Q 1111-09019, Drift Calculation for Rosemount Range Codes 5-8 Gage Pressure Transmitters 3.1.32 GGNS-NE-II-000ll, RCIC Turbine Exhaust Vent Line Trip And Low Steam Pressure Trip And Isolation AL Bases For 24 Month Fuel Cycle 3.1.33 J 1507A, Instrument Location Auxiliary Building & Containment Plan At Elevation 139 Feet 147 & 4 & 7 Inch 3.1.34 J0400, Control Room Panel Location 3.1.35 J0401, Upper Cable Spreading Room Panel Location 3.1.36 A0120, Control Building Control Room Floor Plan at Elevation 166 Feet 3.2 Cross References 3.2.1 Technical Specifications, Table 3.3.6.1-1 3.2.2 Technical Specifications, Table TR3.3.6.1-1 3.2.3 Asset Suite Equipment Data Base (EDB) 3.2.4 "Flow Measurement Engineering Handbook" by R.W.Miller, published by McGraw-Hill Book Company, 1983, pg.6-11 3.2.5 UFSAR Section 5.4.6 3.2.6 ASME Steam Tables, Sixth Edition

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4.0 GIVEN 4.1 Instrument Loop Block Diagram Loop Transmitter Trip Unit Diagram IE31- E21K702 (E21-lE31-PT-N085A,B PS2)

PIS-N685A,B 3.1.4 3.1.2 E12K701 (EI2-PSI)

PT PIS

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4.2 Transmitter Environment (lE31-PT-N085A,B)

Description Data Reference Tag Number 1E31-PT-N085A,B Instrument Location:

Panel IH22-P004, P015 3.1.2 Room IA313 3.1.27,3.1.33 Environmental Conditions:

Normal: Zone N-068 3.1.11 Temperature 60-105°F 3.1.11 Pressure -1.0 to -0.1 in.wg. 3.1.11 Radiation (Gamma) 3.1 E03 rads (40 yr TID) 3.1.11 0.0 II Radslhr gamma 3.1.11 Humidity 20 to 900/0 RH 3.1.11 DBE or Accident: N/A Section 2.0 Seismic Conditions: Not Required Section 2.0 Surveillance Intervals: 24 months 3.2.1 4.3 Trip Unit Environment Description Data Reference Tag Number 1E31-PIS-N685A,B Instrument Location:

Panel IHI3-P629, P618 3.1.2 Room OC703/0C504 3.1.26,3.1.34- 3.1.36 Environmental Conditions:

Normal: Zone N-028 3.1.11 Temperature 69-90°F 3.1.11 Pressure 0.1 to 1.0 in wg. 3.1.11 Radiation (Gamma) 1.8E2 rads (40 yr TID) 3.1.11 0.5 mRadslhr dose rate Humidity 20 to 50% RH 3.1.11 DBE or Accident: Same as Nonnal 3.1.11 Surveillance Intervals 92 days 3.2.1

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4.4 Transmitter Vendor Data Description Data Reference Tag Number IE31-PT-N085A,B Manufacturer Rosemount 3.1.12,3.1.14,3.1.15 Model 1152GP7N22T0280PB 3.1.12,3.1.14,3.1.15 URL 300 psig 3.1.9 Maximum span 0-300 psi 3.1.9 Minimum span 0-50 psi 3.1.9 Calibrated Span 200 psi 3.1.8 Accuracy: +/- 0.25% span (30') 3.1.9, 3.1.5 Drift: +/- 1.3460/0 Span for 30 months 3.1.31 Power Supply: <0.005% span per volt (30') 3.1.9, 3.1.5 Temperature: +/- 5.00% Span/lOOop @ min span (30') 3.1.9,

+/- 1.25% Span/lOOop @ max span (3cr) 3.1.5 Humidity: Sealed unit - no effects 3.1.9 Radiation: +/-5.00% URL 3.1.9 Static Press: N/A for gauge pressure transmitter 3.1.9 Overpressure: < +/- 3.00% URL per 2000 psi (30') 3.1.9, 3.1.5 Seismic: +/- 0.25% URL for 3g peak 3.1.9 Output Range 4-20 madc 3.'1.9 Process Head Correction: lE31-PT-N085A = +2.4 psi 3.1.8 lE31-PT-N085B = +14.5 psi 3.1.8

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4.5 Trip Unit Vendor Data Description Reference Tag Number lE31-PIS-N685A,B Manufacturer Rosemount 3.1.16 - 3.1.18 Model 510DU/710DU 3.1.16 - 3.1.18 Assumption 5.4 Repeatability: +/- 0.2% span 3.1.10, Note 1 Drift: N/A Assumption 5.7 Input Range 4-20madc 3.1.10 Note 1: Table 5 ofreference 3.1.10 defines environmental conditions at the Trip Switch in terms of "operating condition" and "environment." Conditions in Zone N-028 are bounded by line 2 defined as "adverse operating conditions" and "normal environment" The corresponding line on Table 6 specifies repeatability under the defmed conditions as

+/-0.2%. This repeatability is valid for six months operation. An allowance for power supply effects, temperature effects, humidity effects, drift and radiation effects are included in the repeatability.

4.6 Power Supplies Power Supply Nominal 24.0 volts Assumption 5.3 Power Supply Variations 23.0 - 28 vdc Assumption 5.3

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4.7 Instrument Tubing Run Data Description Reference Tag Number IE31-PT-N085A; B Room lA313 3.1.20, 3.1.21 ,3.1.27 Nonnal Temp (N-068) 60-105°F 3.1.11 Accident Temp N/A Section 2.0 Vertical Rise (ft) 8' 3" (IE31-PT-N085A) 3.1.20,3.1.21 7' 6-3/4" (IE31-PT-N085B) 3.1.22,3.1.23 Room IAI12 3.1.22 - 3.1.25 ,3.1.27 Nonnal Temp (N-003) 65-150°F 3.1.11 Accident Temp N/A Section 2.0 Vertical Rise (ft) 12' 3-112" (IE31-PT-N085A) 3.1.21

+21' 0" (IE31-PT-N085B) 3.1.22, 3.1.24

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CALCULATION NO. JC-OIE31-N685-1 REV._....:1'---__

5.0 ASSUMPTIONS 5.1 All uncertainties given in vendor data specifications are assumed to be 2 sigma unless otherwise specified.

5.2 Per reference 3.1.1, the M&TE error is normally assumed to be equal to the reference accuracy of the transmitter. Per reference 3.1.8, a Fluke 45 (+/-0.040 ma, Ref. 3.1.6) and a pressure gauge (+/-0.5 psi) are used to calibrate the transmitters.

The total M&TE error (MTEcall) for this device is the SRSS of the two.

Converting the ma error to psi: (0.040 ma)(200 psi / 16 rna) = 0.5 psi. The SRSS of 0.5 and 0.5 is +/-0.71 psi. The setting tolerance from reference 3.1.8 is +/-0.04 rna, or +/-0.5 psi. As the test equipment error is larger than the reference accuracy of the transmitter (+/-0.34 psi) and the setting tolerance, +/-0.71 psi will be assumed for the M&TE error.

Per reference 3.1.13, a Rosemount readout assembly is used to calibrate the Rosemount trip units. Per reference 3.1.10, the accuracy of the readout assembly (MTE caI2) is +/-0.01 ma, which is equal to (0.01 ma)(200 psi/16 ma) = +/-0.13 psi and the accuracy of the trip unit is to.20% span = 0.20%(200 psi) = +/-0.40 psi.

Reference 3.1.13 specifies a setting tolerance of +/-0.04 ma = (0.04)(200/16) = 0.5 psi. The larger +/-O.5 psi setting tolerance value will be assumed for the M&TE error.

5.3 A maximum value of 28 vdc and minimum of 23 vdc will be assumed for power supply variation, as this is the value provided in PPD 184C4571 for the 24 vdc power supplies (Ref. 3.1.19). This results in an assumed voltage variation of +4, -

I vdc. Per reference 3.1.3, the loop power supplies were replaced with a Vicor model VI-N53-IM DC-DC converter that has a maximum variation of 0.55%,

which is bounded by the original power supply variation. For conservatism, +/-4 vdc wi II be used in this calculation.

5.4 Since Rosemount 51 ODU model is obsolete, they may be replaced with 71 ODU models in the future (Ref. 3.1.29). The performance specifications for the 710DU is equal to or better than those of the 51 ODU.

5.5 Overpressure consists of pressure above the URL, in this case 300 psi (Section 4.4). Nonnally, the transmitter sees full RCS pressure, approximately 1150 psi.

Therefore, the transmitter may see overpressure conditions prior to performing its trip function. Since overpressure is a non-linear effect, the full value will be used.

5.6 The radiation drift for the transmitters and trip units is assumed to be negligible because of the low normal dose rates. Per reference 3.1.7 section 2.6, there is no effect on transmitters below 0.1 Mrad.

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CALCULATION NO. JC-OIE31-N685-1 REV._....:::-_ _

5.7 The accuracy of the Rosemount trip units (+/-0.20% span) is valid for six months (Ref. 3.1.10). The trip units are calibrated every 115 days (Assumption 5.9).

Therefore, drift is included in reference accuracy.

5.8 Harsh environments may affect the cabling by reducing insulation resistance.

Since this loop does not have to work during accident conditions (Section 2.0), no cable degradation is expected and IR = +/-O.O psi.

5.9 A calibration interval of 30 months will be assUtned for the transmitters, which is the nominal 24-1TIOnth period, plus a 25% grace period (Ref. 3.2.1). A calibration interval of 115 days will be assumed for the trip units which is the nominal 92 day period, plus a 25% grace period (Ref. 3.2.1).

5.10 This loop does not employ a primary element separate from the pressure transmitter. Therefore, no additional errors due to inaccuracies in the primary element exist and PE = +/-O.O psi.

5.11 Three sources of process measurement error exist in this application: one due to the water filled tubing, one due to the location of the tap on the piping, and the other due to ambient pressure during accident conditions.

1. Process Measurement errors can arise from changes in density of water in sensing line (tubing) used to connect the transmitter to the process line. Since the error is in a definite direction, the PM error will be a bias term. Each tubing run is sufficiently different that maximum error will be calculated for each tubing run and the largest error used in the calculation.

The method used will be to compare the calibrated static head correction to the static head conditions during the minimum and maximum environmental conditions. This is done by summing the heads due to each of the vertical lengths in different environments. The difference between these values will be the change due to actual plant conditions, which is the process measurement error desired.

Head = ~ [vertical length

• density]

Process Measurement Error = Head (actual) - Head (calibrated)

(Note that if the actual static head is higher than the calibrated head, the transmitter output will be higher than desired: a positive PM error).

For N085B loop, the PM error will be determined for the minimum temperature and maximum pressure (1150 psig, Assumption 5.5) during normal conditions and the maximum temperature and minimum pressure (0 psig, conservatively) during normal conditions. For the N085A loop, because the transmitter is located above the penetration and the static head effect is reversed for the length of tubing between the penetration and the transmitter,

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~ ENTERGY tJ{f'S SHEET 16 OF-.iL CALCULATION NO. JC-OIE31-N685-1 REV._~_ _

the temperature/pressure extremes for that portion of tubing will be reversed as well. Per section 2.0, these loops are not required to operate during accident conditions. Section 4.7 lists the environments and vertical runs. The various water densities for these temperature and pressures can be found in reference 3.2.6. Note that:

density (lb/ff) I 1728 = density (lb/in3)

Loop: N085A Calibration Process Head Correction: 2.4 psi (Ref. 3.1.8)

Max Static Head Conditions Length Temp Press Density Head

-99 in 105°F o psig 61.931b/re -3.548 psi 147.5 in 65°F 1150 psig 62.57 tb/ft3 5.341 psi Maximum Static Head +1.793 psi Min Static Head Conditions Length Temp Press Density Head

-99 in 60°F 1150 psig 62.60 tb/ff -3.586 psi 147.5 in 150°F o psig 61.191b/ft3 5.223 psi Minimum Static Head +1.637 psi Loop N085A PM (max static head) = -0.607 psi PM (min static head) = -0.763 psi

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tzt: CALCULATION SHEET SHEET 17 OF--iL CALCULATION NO. JC-OIE31-N685-1 REV._-:.-_ _

Loop: N085B Calibration Process Head Correction: 14.5 psi (Ref. 3.1.8)

Max Static Head Conditions Length Temp Press Density Head 90.75 in 60°F 1150 psig 62.601b/ff 3.288 psi 252 in 65°F 1150 psig 62.57 Ib/n3 9.125 psi Maximum Static Head +12.413 psi Min Static Head Conditions Length Temp Press Density Head 90.75 in 105°F Opsig 61.93 Ib/ft3 3.252 psi 252 in 150°F opsig 61.19 Ib/ft3 8.924 psi Minimum Static Head +12.176 psi Loop N085B PM (max static head) = -2.087 psi PM (min static head) = -2.324 psi Because this is a decreasing setpoint, negative bias errors need not be considered. Therefore, the PM error due to density variation is zero.

2. The loop employs elbow taps in the main steam line for pressure measurement points. The flow around the elbow causes a high pressure area on the outside of the elbow and a low pressure area on the inside, the square root of the difference being proportional to the flow (Ref. 3.2.4).

IE31-PT-N085A taps off the outside of an elbow. This results in PT-N085A reading higher than actual system pressure, a positive bias error. IE31-PT-N085B taps off the inside of the elbow. The effects are exactly the same, but results in lE31-PT-N085B reading lower than system pressure, a negative bias error.

lE31-PDT-N084 measures this differential pressure and generates a trip signal on high differential pressure corresponding to high steam flow, an indication of a steam line break. From reference 3.2.1, the allowable value for this trip is 64 inwc. Half of this is due to elevating the pressure at the outer tap, half due to the drop at the inner tap (Ref. 3.2.4).

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CALCULATION NO. JC-OIE31-N685-1 REV. 1 _

Therefore, IE31-PT-N085A will read from 0 to 32 inches high as flow varies from 0 to the allowable value. This must be treated as a positive bias error, since it always makes the reading high.

Similarly, lE31-PT-N085B will read from 0 to 32 inches low as flow varies from 0 to the allowable value. This must be treated as a negative bias error.

Since this will cause an early trip, no credit will be taken for it, and the worst case value will be used:

PM = +32 inches

= +1.16 psi

3. The final source of process error arises from the fact that 1E31-PT-N085 actually measures differential pressure between the process and local ambient pressure (psig). Since this loop does not have to work during accident conditions (Section 2.0), no significant variation in local ambient pressure is expected (Section 4.2), and no error will exist due to this effect.

CALCULATION SHEET SHEET 19 OF--!l-CALCULATION NO. JC-OIE31-N685-1 REV._~ __

6.0 METHODOLOGY 6.1 Device Uncertainties For each module, the uncertainty terms applicable to this application will be specified and combined into the following module errors:

RA reference accuracy L negative bias uncertainty M positive bias uncertainty MTE - measurement and test equipment inaccuracies D drift 6.2 Loop Uncertainties The random and bias components of:

PE errors associated with the Primary Element PM errors in Process Measurement, and IR errors due to degradation in Insulation Resistance will be quantified, the loop error equation given, and the device and loop uncertainties combined to produce:

AL SRSS of all device random uncertainties except Jrift LL The sum of all negative bias uncertainties ML The sum of all positive bias uncertainties CL SRSS of all measurement and test equipment ,., 'lccuracies used for calibration.

DL SRSS of all drifts LU SRSS( AL, C L, PE, PM ) +/- IR - LL + ML 6.3 Total Loop Uncertainty The total loop uncertainty will be calculated using the reterence 3.1. L equation:

TLU=LU+D L 6.4 Allowable Value The allowable value for the loop will be calculated using the C""nce 3.1.1 equation:

AV=AL+/-LU

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CALCULATION NO. JC-OIE31-N685-1 REV._--=--_ _

6.5 Nominal Trip Setpoint The nominal trip setpoint will be calculated using the reference 3.1.1 equation:

NTSP = AL +/- TLU 6.6 Spurious Trip Avoidance The probability of a spurious trip during nonnal plant operation using the Tech Spec setpoint will be evaluated using the methodology of reference 3.1.1 and calculated loop errors. Per reference 3.1.1, a 95 % probability of no spurious trip is acceptable.

6.7 LER Avoidance The probability of exceeding the Tech Spec allowable value without a trip at the tech spec setpoint will be evaluated using the methodology of reference 3.1.1 and calculated loop errors. Per reference 3.1.1, a 90% probability of avoiding LERs is acceptable.

Note: When considering the probability of a spurious trip, any late actuation will be conservative. Similarly, when considering the probability of an LE~ any early actuation will be conservative. This means that single sided distributions are appropriate for this evaluation. Per reference 3.1.1, a Z of 1.645 corresponds to a probability of 95%. Similarly, a Z of 1.28 corresponds to a probability of 90%.

6.8 Nomenclature The nomenclature of reference 3.1.1, Section 1.6, will be used. Errors associated with the transmitter will be subscripted with a "1", errors associated with the trip unit will be subscripted with a "2", while loop errors will be subscripted with an "L". For example, 01 would be the transmitter drift, D 2 would be the trip unit drift, and D L would be the loop drift.

6.9 Worst Case Loop The equipment and environments for each loop are identical; therefore, no worst case calculation is required.

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7.0 CALCULATION 7.1 Transmitter Uncertainties Using the vendor data from Section 4.4:

URL = 300 psig SPAN = 200 psi RA l = +/- 0.25% span (30)

= +/- (2/3)*(0.0025)*(200) psi

= +/- 0.34 psi Temperature effect is specified at maximum and minimum span (Section 4.5).

Maximum and minimum spans are 300 psi and 50 psi (Ref. 3.1.9). Using a linear interpolation between these values for the temperature effect at 200 psi:

(Cal Sp - Min Sp) = (X- TE @ Min Sp)

(Max Sp - Min Sp) (TE @ Max Sp - TE @ Min Sp)

(200 - 50) (X- 5.00)

(300 - 50) (1.25 - 5.00) 150*(-3.75) = 250X - 1250 x = (150*(-3.75>> + 1250 250 X= 2.75

= +/- 2.75% Span/100°F (30)

= +/- (2/3)*(0.0275)*(200 psi)

= +/- 3.67 psi/lOO°F Temperature effect will be broken into TD (65-90°F per reference 3.1.1), TEN (90-1 05°F, the balance of the normal range from Section 4.2). Per Section 2.0, no accident conditions need to be addressed.

Therefore:

TD l = (3.67)*(25/100)

= +/- 0.92 psi TENl = (3.67)*(15/100)

= +/- 0.56 psi

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CALCULATION SHEET JC-OIE31-N685-1 SHEET 22 OF-.!L REV._-=--_ _

Per reference 3.1.9, humidity has no effect on the sealed transmitter.

HEl == +/- 0.00 psi Radiation Drift (normal)

ROI == +/- 0.00 psi Assumption 5.6 Per Section 4.6, the worst power supply variations arc taken as +/- 4.0 volts.

== +/- 0.005°,,10 span / volt variation (30)

== +/- (2/3)*(0.00005)*(200 psi)*(4 volts)

== +/- 0.03 psi Seismic Effect

== +/- 0.00 psi Section 2.0 Overpressure Effect OVP 1 == +/- 3.0% URL for 2000 psi (30) Assumption 5.5

== +/- (2/3)*(0.03)*(300 psi)

== +/- 6.00 psi Drift

== +/- 1.346% Span for 30 months

== +/- (0.01346)*(200 psi)

== +/- 2.70 psi Summarizing for the transmitter:

== +/- SRSS(RAJ, TEN" PSI, SEJ, OVP I )

== +/- SRSS(0.34, 0.56, 0.03,0.00, 6.00)

==+/- 6.04 psi

== + 0.0 psi

= - 0.0 psi

== +/- 0.71 psi Assumption 5.2

== +/- SRSS(DR 1, TOI)

== +/- SRSS(2.70, 0.92) psi

== +/- 2.86 psi

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7.2 Trip Unit Uncertainties Using the vendor values from Section 4.5:

Span = 200 psi A2 = +/- 0.20% span

= +/- (0.0020)*(200 psi)

= +/- 0.40 psi L2 = + 0.00 psi M2 = - 0.00 psi

= +/- 0.50 psi Assumption 5.2

= +/- 0.00 psi Assumption 5.7 7.3 Primary Element Accuracy PE =+/-O.O psi Assumption 5.10 7.4 Process Measurement Accuracy PM = +1.16 psi Assumption 5.11 7.5 Insulation Resistance Bias IR = 0.0 psi Assumption 5.8 7.6 Loop Uncertainties Using the equations from reference 3.1.1 and the values from above:

AL = +/- SRSS(A 1, A2)

= +/- SRSS(6.04, 0.40)

=+/- 6.06 psi LL = L1 + L2 = -0.0 psi ML = M 1 + M2 = +0.0 psi CL = +/- SRSS(C" C z)

= +/- SRSS(O.71, 0.50)

= +/- 0.87 psi

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CALCULATION SHEET JC-OIE31-N685-1 SHEET 24 OF REV._-=--_ _

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DL = +/- SRSS(D" D2)

= +/- SRSS(2.86, 0.00)

=+/- 2.86 psi LU+ = + SRSS(AL, Cd + PM

= + SRSS(6.06, 0.87) + 1.16

= + 7.29 psi 7.7 Total Loop Uncertainty TLU =LU++DL

=7.29 + 2.86

= + 10.15 psi 7.8 Allowable Value AV =AL+LU+

=50+7.29

= 57.29 psig The Technical Specification Allowable Value of~ 53.0 psig, is non-conservative with respect to the calculated AV value.

Based on the reference 3.1.1, section 7, statistical techniques may be considered to reduce margin. Because the setpoint is approached from only one direction and there is no increasing setpoint, the setpoint errors (LU) have a single side of interest and may be reduced by a factor of 1.645 / 2 to maintain a 95% probability of a trip.

LU'+ = <<LU+ - PM)* 1.645 /2) + PM_

= <<7.29- 1.16)* 0.8225) + 1.16

= 5.05 + 1.16

= + 6.21 psi AV' = 50 + 6.21

= 56.21 psig The calculated AV does not support the existing Technical Specification Allowable Value of~ 53.0 psig. Therefore a new technical specification allowable value of~ 57 psig is recommended.

CALCULATION SHEET SHEET 25 OF-!L-CALCULATION NO. JC-OIE31-N685-1 REV._...:1~__

7.9 Nominal Trip Setpoint NTSP = AL + TLU

== 50 psig + 10.15 psi

= 60.15 psig The Technical Specification NTSP of ~ 60.0 psig, is non-consetvative with respect to the calculated NTSP value.

Per Section 7 of reference 3.1.1, TLU may be reduced by using the single-sided distribution and SRSS (LU,Dd methods. Therefore:

TLU' == (l.645/2)(SRSS(LU+, DL))

= (0.8225)(SRSS<<7.29 - 1.16),2.86)) + 1.16

= + 6.73 psig Recalculating NTSP NTSP' = AL + TLU'

= 50 + 6.73

= 56.73 psig The Technical Specification NTSP and plant setpoint of 60 psig is consetvative with respect to the calculated value.

7.10 Spurious Trip Avoidance Z = ABS(NTSP - XT) / SRSS(Sigman, Sigmai) where:

Sigmai = (IIn)*(SRSS<<LU'+- PM), Dt})+ PM Ref. 3.1.1 n =2 Assumption 5.1 Sigmai = (l/2)*(SRSS<<6.21 - 1.16), 2.86)) + 1.16

== 4.07 Reference 3.2.5 notes that the RCIC turbine steam input pressure in the LP (Low Pressure) Condition cannot fall below 135 psig. Trips below this limit would not be considered spurious since there is no longer any need for the RCIC turbine.

Xr = 135 psi The confidence of this XT is high; therefore, the appropriate value of SigmaN is zero.

SigmaN = 0.00

~ENTERGY ~'~_i c' - CALCULATION SHEET SHEET 26 OF--4!-

CALCULATION NO. JC-OIE31-N685-1 REV._~__

Using the equations from reference 3.1.1 and the NTSP from Section 2.0:

Z = ABS(NTSP - XT) / SRSS(SigmaN, Sigmai) Ref. 3.l.1 Z = ABS(60 - 135) I SRSS(O.OO, 4.07)

= 18.42 This is above the Section 6.6 minimum acceptable Z value of 1.645 for 95%.

7.11 LER Avoidance Using the recommended AV of 57 psig from section 7.8:

Z = ABS(AV- NTSP) / lIn*SRSS(AL , CL, DL) Ref. 3.l.1

= ABS(57 - 60) I ~ SRSS(6.06, 0.87, 2.86)

=0.88 This is below the Section 6.7 minimum acceptable Z value of 1.28 for 90%.

CALCULATION SHEET SHEET 27 OF ~

CALCULATION NO. JC-OIE31-N685-1 REV._-=l _

7.12 As-Left Tolerance Note: For the purposes of calculating ALT, the actual MTE values, MTEleal and MTE2eal, are used.

ALTT - Transmitter TSTF-493 Calculation MTE lcal +/- 0.71 psi Assumption 5.2 ALTT +/- SRSS (RAI, MTElcal)

= +/- SRSS (0.34, 0.71) psi

+/- 0.79 psi Converting to loop current:

ALTT = +/- (0.79 psi/200 psi)*16 rnA

= +/-0.06rnA ALTTeal - Transmitter As-Left Tolerance for Calibration Procedures In field calibration procedures, use only the Reference Accuracy (RA) for establishing the Transmitter ALT.

ALTTcal = RA I = +/-0.34 psi Converting to loop current:

ALTTeal = +/- (0.34 psi/200 psi)

• 16 rnA

= +/-0.03 rnA The current calibration setting tolerance for the transmitter is +/- 0.04 rnA, which is conservative to the TSTF-493 required value. Because of perceived difficulty in calibration to the derived value, the current ALT is retained.

ALTTeal = +/- 0.04 rnA ALTTU - Trip Unit TSTF-493 Calculation MTE2cai +/- 0.13 psi Assumption 5.2 ALTru +/- SRSS (A2, MTE2ea l)

= +/- SRSS (0.40, 0.13)

= +/- 0.42 psi

~ ENTERGY CALCULATION NO.

CALCULATION SHEET JC-OIE31-N685-1 SHEET 28 OF-+/-L REV._....:-_ _

Converting to loop current:

ALTru == +/- (0.42 psi/200 psi)

• 16 rnA

=+/-0.03 rnA ALTTUeal - Trip Unit for Calibration Procedures In field calibration procedures, use only the Reference Accuracy (RA) for establishing the Trip Unit ALT.

ALTTUeal == A2

== +/- 0.40 psi Converting to loop current:

ALTrueal == +/- (0.40 psi/200 psi)

• 16 rnA

== +/- 0.03 rnA 7.13 As-Found Tolerance (AFT)

AFTT- Transmitter TSTF-493 Calculation For calculating AFTT, the actual MTE value is used:

AFTT == +/- SRSS (RAI, MTEleal, D.) psi

== +/- SRSS (0.34, 0.71, 2.86) psi

== +/- 2.97 psi Converting to loop current:

AFTT == +/- (2.97 psi/200 psi)

• 16 rnA

== +/-0.24mA AFTTeal - Transmitter As-Found Parameter for Field Procedures Defining AFTTeal, the value used in calibration procedures for monitoring perfonnance:

Surveillance Interval == 30 Months DR. == +/-2.70 psi AFTTeal == DRI

== +/-2.70 psi

== +/- (2.70 psi/200 psi)

• 16 rnA

+/-0.22 rnA AFTTU - Trip Unit TSTF-493 Calculation The surveillance period for the trip units is 115 days.

-=- ENTERGY CALCULATION NO.

CALCULATION SHEET JC-OIE31-N685-1 SHEET 29 OF ~

REV.. _..;;...._ _

Using vendor data, AFTru +/- SRSS (Az, MTEzcal, Dz)

== +/- SRSS (0.40,0.13, 0) psi

= +/- 0.42 psi Converting to loop current:

== +/- (0.42 psi/200 psi)

• 16 rnA

== +/- 0.03 rnA AFTrucal- Trip Unit As-Found Parameter for Field Procedures Surveillance Interval = 115 Days Dz = +/-O.OO psi Because there is no drift value for the trip unit, AFTTUcal will be set equal to AFTru .

AFTTUcal = AFTru

= +/-0.42psi

+/- (0.42 psi/20Opsi)

• 16 rnA

= +/-0.03 rnA 7.14 Loop Tolerances ALTL - As-Left Loop Tolerance ALT L == +/- SRSS (ALTTcaJ, ALTrucal )

+/- SRSS (0.34, 0.40) psi

+/- 0.52 psi

= +/- (0.52 psi/200 psi)

• 16 rnA

+/-0.04rnA AFTL - As-Found Loop Tolerance AFTL = +/-SRSS (AFTTcaJ, AFTrucal)

= +/-SRSS (2.70, 0.42) psi

= +/- 2.73 psi

+/- (2.73 psi/200 psi)

• 16 rnA

+/-0.22 rnA

-=- ENTERGY CALCULATION NO.

CALCULATION SHEET JC-Q 1E31-N685-1 SHEET 30 OF....4l-REV._.....:-_ _

8.0 CONCLUSION

The Technical Specification allowable value is non conservative with respect to the calculated values. The Technical Specification NTSP is conservative with respect to the calculated values. Using the recommended AV yields unfavorable LER avoidance.

SUMMARY

OF RESULTS SYSTEM E31 LOOP NUMBERS N685A,B TOTAL LOOP UNCERTAINTY +6.73 psi LOOP UNCERTAINTY + 6.21 psi DRIFT ALLOWANCE +/- 2.86 psi M&TE +/- 0.87 psi SPECIFIED (psig) CALCULATED (psig)

Design Limit 50 -

Allowable Value ~53 56.21

> 57**

Nominal Trip Setpoint >60 56.73

• • Recommended value Summary of Calibration Tolerances Transmitter As-Left Tolerance TSTF-493 (ALTT) +/-0.06rnA Transmitter ALT Cal (ALTTeal) +/-0.04rnA Trip Unit As-Left Tolerance TSTF-493 (ALTTu ) +/-0.03 rnA I Trip Unit ALT Cal (ALTTueal) +/-0.03 rnA Transmitter AFT TSTF-493 (AFTT) +/-O.24mA Transmitter AFT Cal (AFTTeal) +/-0.22 rnA Trip Unit AFT TSTF-493 (AFTTV) +/-0.03 rnA Trip Unit AFT Cal (AFTTUeal) +/-0.03 rnA As-Left Loop Tolerance (ALTd +/-0.52 psi I As-Left Loop Tolerance (ALT d +/-0.04rnA As-Found Loop Tolerance (AFT l) +/-2.73 psi As-Found Loop Tolerance (AFTt} +/-0.22 rnA

ATTACHMENT 1 JC-Q1 E31-N685.1 r REV. 1 DesIGN VERIFICATION SHEET 31 OF 41 Sheet I of 1 DESIGN VERIFICATION COVER-PAGE o ANQ-1 o ANQ-2 o IP-2 OIP-3 DJAF OPlP OPNPS OVY 181 GGNS ORBS OW3 DNP Document No. JC-Q1EJ J-N68S-1 r Revision No. 1 I Page 1 of4

Title:

lnstnonent Loop Uncertainty and SetpoiDt Determination for System E31 Loop N685 ReTe Turbine Isolation on Low Inlet Steam Pressure

~ Quality Related o Augmented Quality Related DVMethod: ~ Design Review o Alternate calculation o Qualification Testing VERIFICATION REQUIRED DISCrPLINE VERIFICATION COMPLETE AND COMMENTS RESOLVED (DV print., si~

and date Electrical Mechanical InsttUment and Control RobbtSmith CiviJIStrootural Nuclear Originator: M 11-1-/2

ATTACHMENT 1 JC-Q1E31-N685*1, REV. 1 DESIGN VERIFICATION SHEET 32 OF 41 ATTACHMENT 9.6 DESIGN VERIFICATION CHECKLIST Sheet 1 of3 IDENTIFICATION:

DISCIPLINE:

Docume nt

Title:

Instrum ent Loop Uncerta inty and Setpoin t Detenni nation for System DCivil/Structural E31 Loop N685 RCIC Turbine Isolation on Low Inlet Steam Pressure OElectr ical Doc. No.: JC-Q 1E31-N685~ I Rev. I QA Cat.: SR 1&11 & C Robin Smith See AS for signatur e Verifier: OMecha nical Print Sign Date ONucle ar Manager authorization for DOther supervisor performing Verification.

I8l N/A Print Sign Date METIIOD OF VERIFICATION:

Design Review I8J Alternate Calculations 0 Qualification Test 0 The followin g basic question s are address ed as applicab le, during the perfonn ance of any design verificat ion. [ANSI N45.2.1 1 - 1974] [NP] [QAPD , Part II, Section 3] [NQA-l -1994, Part II, BR 3, Supplem ent 3s-1].

NOTE The reviewe r can use the "Conun entsiCo ntinuati on sheet" at the end for entering any commen t/resolu tion along with the appropr iate question number.

Additio nal items with new question number s can also be entered.

1. Design Inputs - Were the inputs correctly selected and incorporated into the design?

(Design inputs include design bases. plant operational conditions, perfonna nce requirements. regulatory requirements and commitments. codes. standards. field data, etc. All infonnat ion used as design inputs should have been reviewed and approved by the responsible design organization.

as applicable.

All inputs need to be retrievable or excerpts of documents used should be attached.

See site specific design input procedures for guidance in identifYing inputs.)

Yes~ NoD N/A 0

2. Assump tions - Are assumptions necessary to perform the design activity adequately described and reasonable?

Where necessary. are assumptions identified for subsequent re-verification when the detailed activities are completed?

Are the latest applicable revisions ofdesign documents utilized?

Yes 181 No 0 N/A 0

3. Quality Assuran ce - Are the appropr iate quality and quality assuranc e requirem ents specifie d?

Yes 181 No 0 N/A 0

ATTACHMENT 1 JC-Q1E31-N685-1, REV. 1 DESIGN VERIFICATION SHEET 33 OF 41 ATTACHMENT 9.6 DESIGN VERIFICATION CHECKLIST Sheet 2 of3

4. Codes, Standards and Regulatory Requirements - Are the applicable codes, standards and regulatory requirements, including issue and addenda properly identified and are their requirements for design met?

Yes ~ No 0 NIA 0

5. Construction and Operati ng Experie nce - Have applicab le construc tion and operating experien ce been considered?

Yes 0 No 0 N/A l8J

6. Interfaces - Have the design interface requirements been satisfied and documented?

Yes 0 No 0 N/A 18I

7. Methods -_. Was an appropriate design or analytical (for calculations) method used?

Yes CBJ No 0 N/A 0

8. Design Outputs - Is the output reasonable compared to the inputs?

Yes l8J No 0 N/A 0

9. Parts, Equipment and Processes - Are the specified parts, equipment, and processes suitable for the required application?

Yes 0 No 0 N/A 18I

10. Materials Compatibility - Are the specified materials compati ble with each other and the design environmental conditions to which the material will be exposed ?

Yes 0 No 0 N/A l8J

11. Maintenance requirements - Have adequate maintenance features and requirements been specified?

Yes 0 No 0 N/A l8J

12. Accessibility for Maintenance - Are accessibility and other design provisio ns adequat e for perform ance of needed maintenance and repair?

Yes 0 No 0 N/A l8J

13. Accessibility for In-service Inspection - Has adequate accessibility been provided to perform the in-service inspection expecte d to be required during the plant life?

Yes 0 No 0 N/A 18I

14. Radiation Exposure - Has the design properly considered radiation exposur e to the public and plant personnel?

Yes 0 No 0 N/A l8J

15. Acceptance Criteria - Are the acceptance criteria incorporated in the design documents sufficient to allow verification that design requirements have been satisfactorily accomp lished?

Yes l8J No 0 N/A 0

16. Test Requirements - Have adequate pre-operational and subsequent periodic test requirements been appropriately specified?

Yes 0 No 0 N/A l8J

ATTACHMENT 1 JC-Q1E31-N685-1, REV. 1 DESIGN VERIFICATION SHEET 34 OF 41 ATTACHMENT 9.6 DESIGN VERIFICATION CHECKLIST Sheet 3 of3

17. Handling, Storage, Cleaning and Shipping - Are adequate handling, storage, cleaning and shipping requirements specified?

Yes 0 No 0 N/A 181

18. Identification Requirements - Are adequate identification requirements specifie d?

Yes 0 No 0 N/A 181

19. Records and Documentation - Are requirements for record preparation, review, approval, retention, etc.,

adequately specified? Are all documents prepared in a clear legible manner suitable for microfilming and/or other documentation storage method? Have all impacted documents been identified for update as necessary?

Yes 181 No 0 N/A 0

20. Software Quality Assurance- ENN sites: For a calculation that utilized software applications (e.g.,

GOTHIC, SYMCORD), was it properly verified and validated in accorda nce with EN- IT-I04 or previous site SQA Program?

ENS sites: This is an EN-IT-I04 task. However, per ENS-DC-126, for exempt software, was it verified in the calculation?

Yes 0 No 0 N/A 181

21. Has adverse impact on peripheral components and systems, outside the boundar y ofthe document being verified, been considered?

Yes 0 No 0 N/A 181

ATTACHMENT 1 JC-Q1E31-N685-1, REV. 1 DESIGN VERIFICATION SHEET 35 OF 41 ATTACHMENT 9.7 DESIGN VERIFICATION COMMENT SHEET Comments / Continuation Sheet Question Comments Resolution InitiaVDate 1 Density-related PM error should be Incorporated. (This section moved to RS / 9-14-12 determined in Assumption 5.14 for normal 5.11 ).

conditions.

ATTACHMENT 2 JC.Q1E31-N685-1, REV. 1 OWNER'S REVIEW COMMENTS SHEET 36 OF 41 A

--=~ Enferg y ATTACHMENT 9.10 ENGINEERING CHANGE COMMENT FORM SHEET 1 OF 1 Commen t Departm ent I Reviewe r Disciplin e 1 Commen t Commen t Date No. Resoluti on Program Date Resolved Owner's R,v'. Commen ts to JC.Q1 E31-N6851 tEe 39554)

General Issues 1 R. EXCEL Section 2: There is no basis 8/10112 The subject paragraph was not affected 09/26112 Hannigan Services reference for the Design Basis by this revision of the calculation and is Corp. Events statement listed in Section not required to be updated. The 2nd

2. Need to add a cross-reference sentence of the paragraph is basically for this. Should also check stating that the suppression pool heatup accident analyses and confinn the caused by RCTC operation has an events credited.

insignificant affect on the surrounding That whole paragraph under envirorunent.

"Design Basis Event (DBE)" is confusing and poorly written. I realize it may be out of Enercon's scope but it would be nice to rework it.

Paragraph under "Design Basis Event (DBEr - What value does the 2nd sentence provide? It appears that the tid sentence is supposed to be the justification for the next sentence stating that these instruments do not have to operate under accident conditions but it isn't clear. Again. this may be out of Enercon's scope.

EN-DC-llS. Rev. 10

AnACHM ENT2 JC.Q1E31*N685-1, REv. 1 OWNER'S REVIEW COMMENTS SHEET 37 OF 41 Commen t Departm ent I Reviewe r Disciplin e I Commen t Commen t Date No. Resoluti on Program Date Resolved Owner*, Review Commen ts to JC-Q1E31*N685-1 lee 39554) 2 R. EXCEL Section 2.0 - 2 nd paragraph under 8/10112 Defined SSE. At GGNS SE in normally 09/26/12 Hannigan Services Design Basis Events - prior to addressed under DBE.

Corp. using terms QF1 and SSE consider defining them.

Also. is this paragraph supposed to be under the "Design Basis Event (DBE)" heading or is it a separate subject, i.e. "Seismic Requirements"? I realize that may change based on new direction from 8/16/2 teleean.

3 R. EXCEL Section 2.0 -last paragraph - if 8110112 Hannigan Added (AL) after design limit. This is 09/26/12 Services the 50 psig Design Limit is going an adequate method of noting this.

Corp. to be used to repface the previous Analytical then it should be clearly This calculation is consistenr with stated in this section. If so then GGNS serpoint calculation format.

for the remainder of the Generally AL and technical calculation you should use the specification values are identified after term Design Limit or "DL".

DBE.

Also, for this section consider not listing the previous AV & NTSP but rather state that this revision will establish new AV & NTSP in association with the 24 Month Project. We know that there are going to be AV and possibly NTSP changes so might as well state it here.

Also. is this paragraph still a sub-part under the heading "Design Basis Event (DBE)" or should there should be a new heading?

EN-De-li S. Rev. 10

ATTACH MENT 2 JC-Q1 E31-N685-1, REV. 1 OWNER'S REVIEW COMMENTS SHEET 38 OF ..1 Commen t Departm ent I Reviewe r Disciplin e I Commen t Commen t Date No. Resoluti on Program Date Resolved Own,r's Rev;ew Commen ts to JC.g1 E31-N615-1 lEe 39554) 4 R. EXCEL R'ferenc e 3.1.9 - need to correct 8/10/12 Changed reference 46000094 4 to 09/26/12 Hannigan Services to 460002635. 460002635.

Corp.

5 R. EXCEL Section 4.2 - The TID rad dose 8/10112 Incorporated.

Hannigan Services for Zone N-068 has been 09/26/12 Corp. changed in E100.0 Rev. 7 to 3.1E3 Rads.

The dose rate has been changed in E100.0 Rev. 7 to 0.011 Rad/hr.

6 R. EXCEL Section 4.3 - The temperat ure for 8110/12 Incorporated. 09126/12 Hannigan Services Zone N-028 has been changed in Corp. E100.0 Rev. 7 to 69 - 90F.

7 R. EXCEL Section 4.4 - Process Head 8/10112 The ~ head stated in the 09/26/12 Hannigan Services Correction referenced in this calculation agrees with reference 3. I.8.

Corp. section differs from that in Ref No change required.

3.1.8 (surv test 06-IC-1E 31-R-1016). The head correction for 1E31-PT-N085A & B is

+2.1/+13.3 psi in surv test va.

+2.4/+14.5 psi in calc.

8 R. EXCEL Section 4.4 - Need to redo 8/10/12 Incorporated the new guidelines Hannigan Services Rosemou nt transmitter 09/26/12 concerning Rosemount transmitter Corp. uncertainties based on new confidence levels into the calculation.

direction regarding 20/30 values.

This should help knock down the Overpressure Uncertainty.

EN-DC-I 15. Rev. 10

ATTACH MENT 2 JC.Q1E3 1-N685-1 , REV. 1 OWNER'S REVIEW COMMENTS SHEET 39 OF 41 Commen t Departm ent 1 Reviewe r Disciplin e 1 Commen t Commen t Date No. Resoluti on Program Date Resolved Owner's Review Commen ts to JC..Q1E31-N§85:1 IEC 39554) 9 R. EXCEL Section 4.7 - When referring to 8110112 Revised tag numbers in section 4.7. 09/26112 Hannigan Services the transmitte rs be consistent with Corp. the tag name - if you are going to express it as 1E31-PT- N085A & 8 then use the same tag id throughout the step and the rest of the calc.

Same for trip units - be consistent with tag names.

10 R. EXCEL Section 5.1- Modifylre move as 8110/12 JIK:orporated based on new guidelines. 09/26112 Hannigan Services per new direction regarding Corp. Rosemou nt transmitte r uncertainty.

11 R. EXCEL Section 5.3 - Why are you using 8110112 Any gains in using different values for 09/26112 Hannigan Services the +/-4 volts if both power supplies power supply effect is negligible siIK:e Corp. have been replaced with the the total power supply effect is 0.03 psi better converters?

currently.

12 R. EXCEL Section 5.14 - When you are 8/10/12 This technique is applied to the A loop 09/26/12 Hannigan Services computin g the Max & Min Static only because the transmitter is located Corp. Head Conditions it appears as above the penetration as explained in though you have sensing lines section 5.14.1. (This section moved to that are seeing 0 psig in one 5.11).

section and 1150 psig in an adjacent connected section. That isn't possible. 00 you really mean to do that?

EN-De-lI S. Rev. 10

ATTACHMENT 2 JC.Q1E3 1-N685-1 , REV. 1 OWNER 'S REVIEW COMMENTS SHEET 40 OF 41 Commen t Departm ent I Reviewe r Disciplin e I Commen t Commen t Date No. Resoluti on Program Date Resolved Owner's Reyiew Commen ts to JC.g1E3 1-NH5-1 IEC 39554) 13 R. EXCEL Section 5.14 - For the loop 8/10/12 This is explained in seclion 5.14.1 in 09/26/12 Hannigan Services N085A & B PM value at the the paragraph preceding the actual Corp. bottom of the table explain how calculations. This is an adequate you derived those values from the method of presenting this material.

table and exacUy what these (This section moved to 5.11).

values mean - it isn't clear. I figured it out but you might want to just add how you came up with the value.

14 R. EXCEL Section 7.1 - The TO, 8/10112 1S09 section 3.2.3 (65F - 90F). 09/26112 Hannigan Services temperat ure effect should be 60F Corp. to 90F - not 65F to 90F. This will affect TD1, 01. and DL computations.

15 R. EXCEL Section 7.1 - Need to redo 8/10112 Incorporated the new guidelines 09/26/12 Hannigan Services Rosemou nt transmitte r concerning Rosemount transmitter Corp. uncertainties based on new confidence levels into the calculation.

direction regarding 20/30 values.

This should help knock down the Overpres sure Uncertainty.

16 R. EXCEL Section 7.1 - Delete seismic from 8/10112 Incorporated the new guidelines 09/26/12 Hannigan Services A 1 computation per new direction.

concerning SE into the calculation.

Corp.

EN-De-li S, Rev. 10

ATTACHMENT 2 JC.Q1E3 1-N685-1 , REV. 1 OWNER 'S REVIEW COMMENTS SHEET 41 OF 41 Comm.n t D.partm ent I Reviewe r Disciplln . , Commen t Comm.n t Date No. Resoluti on Program Date Resolved Own....' Rev;.w Commen ts to JC.Q1E3 1.N685-1 (Ee 39554) 17 R. EXCEL Section 7.8 -If we adopt the 8110112 See response to item 3. 09/26112 Hannigan Services Design Limit then replace AL with Corp. DL.

Also. should we change the approach to go from saying that the AV is non-conservatlve to saying that we are establishing a new AV in association with the 24 Month Project? This may be outside your scope or direction -

if so disregard.

18 R. EXCEL Section 7.9 - If we adopt the 8110112 See response to item 3. 09/26/12 Hannigan Services Design Limit then replace Al with Corp. DL.

19 R. EXCEL Section 7.10 -In the sentence 8110112 (ncorporated. 09/26/12 Hannigan Services starting with "Reference 3.2.5 Corp. notes ...* define term "LP" before using it.

20 R. EXCEL Section 8.0 - The AV will 8110112 GGNS to determine. Left as is. 09/26/12 Hannigan services definitely be exceeded although Corp. you may be ok with the NTSP.

Would it be better to say in this section that new AV and NTSP values are being generated to support the 24 Month Projec?

EN-De-liS, Rev. 10

Attachment 5 GNRO*2012/00132 JS09 Revision 1 "Grand Gulf Nuclear Station Instrument and Control Standard Methodology For The Generation Of Instrument Loop Uncertainty & Setpoint Calcu lations"

Engineering Change Mark-up EC#: 39605 [Page 1 of 7 DOC#: JS09 lSHT # 0 TREY 1 Before View 0 I Control Room Drawing: 0 Supersedes l\tlark-up from EC #: NtA IIssued per ECN #: NIA Tim Bryant 9/21/12 See AS Prepared By: Date Reviewer Name (Optional)

STANDARD NO.: OONS-JS-09 REVISION: I PAGE 3 of 32 SECTION 1: PURPOSE The pwpose ofthis engiN.'"Crins !ltandard is to provide the user with the buic tel'D'linology and methodology to be employed in the generation of in.strument loop uncertainty and setpoint calculations at GGNS. lbis ~ when used in col\iunction withP.Jlttep PM'."'"

--.liJ~It'ft, will promote uniformity in instrument loop uncertainty and setpoint caIcuJations genaated b Desi E* . .na-

e. .- O~- 20-0 SECTION 2: SCOPE and ORGANIZATION This standard is based on (SA RP67.04 Part II. 1994. - Methodolosies fOl the .Delennination of SetpoiDts for Nuclear Safety-Related (nstrumaJtation and NEDC 31336P-A. 1996** 0eneraI Electric Ins1nunent SeqJoint Medaodology.

The topical areas 6S1Cd below are discussed in the following sections of this document:

• Terminology to be used in the geaeration of instrument loop uncertainty and serpoint calculations (Section 3)

• Methodology to be used in the generation ofsetpoint calculations for Nuclear Safety-Related Instrumentation which arc addI:aacd in the OGNS Tochn.icaJ Specifications

{Section 4)

• Methodology to be used in the generation of setpoint calculations for Nuclear Safety-Related InlU'umentalion whidldo not fonn a part ofthc GONS Technical Spcc:ilkatioas (Section S)

• Methodology to be used in the generation ofgeneral instrument indication unc:c:rtainty calcuJations (Section 6)

• Methods to be used to increase calculated margins (Section 7)

• Methodology for determining the probability of Spurious Trips and the probability of OCClll1'el1CC ofevents which would result in Licensee Event Reports (Appendix A)

• Analytical techniques for detennining possible measunmteDt uncertainty effc:ds due to 3pecific process variations (Appendix B)

• Analytical techniques for determining possible measurement uncertainty due (0 degraded loop insulation reaistance (Appendix C)

Engineering Change Mark-up Continuation Sheet Before View 0 IEC #:39605 IPage 2 of 7 Doc#:JS09 SHYlO IREV 1

STANDARD NO.: OGNS-JS.09 REVISION: I PAGE 7 of 32 RgJeatability Repeatability is defined as the closeness ofagreement among a nwnber of consecutive measurements of the output for the same value of the input under the same operating conditions approadling from the same d~ion, for fUJI range transverses. [Ref.. 8.2) 3.2.3 Temperature Effects - TE Temperature Effects are defined as the changes in the input/output relationship of a device due to fluctuations in the ambient temperature to which the deviee is exposed.

This effect may only be assumed to be applicable for temperature variations outside the asswned normal calibration temperature range of 65Q F to gooF (i.e. from the minimum expected ambient temperature to 6SQ F or from 9()OF up to the maximum expected ambient temperature). The cffms ofteJDperaturc variations within the calibration temperature band must be addressed meier Temperature Drift effects (See Section 3.2.12). [Ref. 8.:1]

3.2.4 Hwnidity Effects - HE Humidity Effects are defmed as the c:hanges in abe input/output relationship ofa device due to fluctuations ill the ambient humidity levels to which the device is exposecl [Ret: 8.3]

3.2.5 Seismic Eff<<tS

• SE Seismic Effects are defmed as the changes in the input/output relationship of a device due to the effects of seismic vibrations durin or after a seismic event. [Ref. 8.3] onsi n of seismic effects is not required in Grand Gulf setpoint or m a unce amty calculations.

A Safe Shutdown Earthquake (SSE) occurring concurrently with a Design Basis Event (DBE) is not considered credible. [Ref. 8.7] If an SSE or OBE were to occur, the plant is required to promptly shutdown. [Ref. 8.11] Prior to re-start, affected transmitters must be re-calibrated. [Ref. 8.7] Seismic Effect errors for seismic events below the OBE threshold are considered insignificant because the OBE threshold is very low (O.075g).

3.2.6 Radiation Effects* RE Radiation Effects are defined as the chanp:s in the input/output relati<mship of a device due to radiation exposme considering both the dose .rate and totaJ dose.

[Ret 8.3)

Engineering Change Mark-up Continuation Sheet Before View 0 IEC #:39605 IPage 3 of 7 DOC#: J809 ISHT #0 IREV 1

STANDARD NO.: OON8-J8-09 REVISION: I PAGE 8 of 32 3.2.7 Power Supply Effects* PS Power Supply Effeds are defined as the changes in the input/output relationship of a device due to fluctuations in the power supply feeding the device. Voltage and/or frequency fluctuations may result in Power Supply Effects. [Ref. 8.1]

3.2.8 Static Pressure Effect - SPE

-Static Pressure Effect is defined as the uncertainty introduced.in .dilfereatial pressure insttuments which are calibrated at a static pressure that is different from the normal operating pressure. SPB may affect both the span and 2eIO ofthe instrument.

3.2.9 Overpressure EffectCl - OVP Ovetpressure Effects are defined as the changes in the inputIoutput relationship ofa pressure sensing device after exposure 10 process pressure in excess ofits specified Upper Range Limit.

3.2.10 Device Drift - DR Drift is define as an undesired change in output over a period of time were change IS unrelated to the input, environment or load. [Ref 8.1]

Uncertaint due to drift is dependent on the calibration frequency of the device. Drift values can eased on published vendor specifications or the va ues can be detennined based on statistical analysis of as-foWldlas-left calibration data per ECH-NE-08-00015 and EPRI TR-103335 rev 1.

3.2.11 Radiation Drift - RD Radiation Drift is defined as the time dependant change in the input/output relationship ofa device that can be directly related to radiation exposure.

3.2.12 Temperature Drift -1D Temperature Drift is defined as the change in the input/output relationship ofa device due to ambient tcmpemture swings over a calibration period.

Engineering Change Mark-up Continuation Sheet Before View 0 lec #:39605 lPage 4 of 7 DOC#: JS09 SHT #I 0 REV 1 STANDARD NO.: GONS-J8-09 REVISiON: 1 PAGE 9 of 32 Temperature Drift effects may be assumed to be applicable only over the expected range oftempemNre during caJibration (typically 65°F to 90°F). The possible uncertainty due to temperature variations outside this range is addressed under Temperature Effeds. (See Section 3.2.3) [Ref. 8.3]

3.2.13 l\.1e,;1Sllremcnt WId Test Equiplneu( En~ts - ~ITE Measurement and Test Equipment Effects are defined as those uncertainties introduced into a device as a result of the uncertainties associated with the e ui ment use to calibrate the device. TE va ues can be based on published specifications of the test equipment. When confirmed to be conservative MTE can be also set equal to either the reference accuracy or the tolerance specified in the calibration procedure (whichever is larger).

3.3 Loop Specific Random Uncertainty Terms 3.3.1 LoopDevkeU~-A, The Loop Device Uncertainty is defmcd as the S(IWII1' root sum ofthe squares (sasS) ofall the individual Device Uncertainty tenns for a given instrument loop. [Ref. 8.3]

3.3.2 Loop Calibration Uncertainty - c..

The Loop Calibration Uncertainty is defined as the SRSS ofall the Measun:mc:nt and Test Equipment effects that may be incum:d during calibration ofeach ofthe devices in a given loop. [Ref. 8.3) 3.3.3 Loop Drift - 0..

The Loop Drift is defined &11 the SRSS ofthe all the drift tenDs for each of the loop devices. The Loop Drift includes (as applicable) aJJowmces for Device Drift, Temperature Drift, and Radiation Drift for each device in the loop. {Ret: 8.3}

3.3.4 Process Measurement Uncertainty* PM Process Measurement Uncertainties are those uncertainties that may be introduced in an instrument loop due to limitations in modeling the physical system; Ol" more commonly, those uncertainties introduced in an inst:rumeDt loop due to fluctuations in the process for which the [ instrumentation cannot automatically com e.

(see Ap endix B) or the eactor water level setpoint calculations, tlie enslty changes In the reactor vessel do not need to be considered when calculating PM error. Per NEDC 31336, only the density changes in the reference and variable legs need to be considered.

STANDARD NO.: JS-09 REVISION: I PAGE 17 of 32 Engineering Change Mark-up Continuation Sheet Before View 0 lEe #:39605 IPage 5 of 7 DOC#: JS09 ISHT'O IREV1 4.6 Spurious Trip and LER Avoidance Analysis A Spurious Trip and LER Avoidance Analysis must be performed as described in Appendix A to demonstrate the acceptability of the setpoint margins. These analyses must be performed for the setpoint that is employed in the field. These analyses are not required for calculated setpoints that are not to be implemented in the field.

4.7 Calculation of As-Left Tolerance - ALT [Ref. 8.9]

For the purposes of calculating the ALT, actual (published) MTE values are used instead of using the assumption that MTE = RA. (Section 4.1.2)

ALT = +/-SRSS (RA, MTE)

Since a smaller ALT is more conservative it is acceptable to ignore MTE and simplify the equation.

ALT=RA 4.8 Calculation of As-Found Tolerance - AFT [Ref. 8.9]

For the purposes of calculating the AFT, the actual (published) MTE value is used instead of the assumption that MTE = RA.

AFT = +/-SRSS (RA, MTE, DR)

Drift values determined by statistical analysis of historical as-foundlas-Ieft calibration data is actually a combination of RA, MTE and DR because there is no deterministic method to separate these individual components. The AFT equation can therefore be simplified when statistically derived drift values are utilized.

AFr=+/-DR 4.9 As-Left Loop Tolerance and As-Found Loop Tolerance [Ref. 8.9]

The equation for As-Left Loop Tolerance would be:

ALTL = +/-SRSS (ALT lcal, ALT2calt ..., ALTxcal)

The equation for As-Found Loop Tolerance would be:

AFfL = +/-SRSS (AFTlcal, AFI'2cal, ..., AFrXcal)

Engineering Change Mark-up Continuation Sheet Before View 0 IEC #:39605 TPage 8 of 7 DOCI: JS09 ISHT.O REV 1 STANDARD NO.: OON8-Js-09 REVISION: I PAOE 31 of 32 6.3 Calcu1alion ofTota1 Loop u~

~

TLU 7,LU ... Rl + B/Qs t.;;,I SECTION 7: METHODS FOR INCREASING CALCuLATED MARGINS Calculations generated using the methodology presented in this st8Ddard may, due to the in-depth tmltmcnt ofthe uncertainty terms, generate setpoint and instrument W1tCI1ainty estimates which are more conservative than previously calculated values.

If in the generation of setpoints and loop Allowable Values, a large diffinnce is noted between the existing and calculated values, various techniques should be considered to isolate and possibly reduce these d~ if appIopriate.

In certain cmJes, the foUowing !!!!I be valid techniques to reduce calculated uncertainty terms:

7.1 Review the environmemallimits to reduce them as necesary to reflect only the specific event roquimncnts for which the device is required to function.

7.2 Review the value used for Insulation Resistance Effects to e~ that it is not overly conservative 7.3 Review the Measurement & Test Equipment values used in the calculation as a term to be reduced, especially if the M&TE values have been assumed to be equal to the Reference Accuracy of the individual loop devices.

7.4 A Single-sided Distribution approach to the Imc:ertainty may be considered. depending on the application. This approach may not be applicable to all setpoints due to the possible impld on operational .--gins or other system aetpointl. Note, ifthis approach is employed, all data should be nonnalimd for SingJe-Sided Distribution.. With the 20 data applied to Single-Sided Distribution. the acancy will cuecd the 95% confidence level.

(See Reference 8.3) 7.5 The Total Loop Uncertainty may be reduced using the square mol sum of the squares approach to tombine the Loop Uncertainty and the Loop Drift. Generally. this approach should be avoided since it minimizes Ihe margin between the loop Allowable Value and the NomiDal Trip Setpoint. Values calculated usina this approach should be reviewed to ensure adequate margin exists between the Nominal Trip Setpoint and the Allowable Value.

Drift values detennined by statistica analysis of historical as-foundlas-Ieft calibration data is actually a combination of RA, MTE and DR because there is no detenninistic method to separate these individual components. If additional NTSP margin is required, this can be credited and the RA and MTE values can be set equal to zero.

Engineering Change Mark-up Continuation Sheet Before View 0 lee #:39605 IPage 7 of 7 DOC': JS09 !SHT.O IREV 1

STANDARD NO.: GGNS-JS009 REVISION: I PAGE 32 of 32 SECTION 8: REFERENCES 8.1 ISA RP67.04, Part II, 1994, Methodologies for the Detennination ofSetpoints for Nuclear Safety-Related Instrumentation 8.2 Process Measurement .. Instnunent Engineers' Handbook Revised Edition Bela G. Liptak & Kristzta Vcncld, 1982

• Chilton Book Co., Radnor Peansylvania 8.3 NEDC-31336P-A, 1996, General Electric Instrumeot Serpoint Methodology W.H. Cooley, JR., J.L. Leong, M.A. Smith, s. Wolf: .. General Electric Co.

8.4 CRANE Technical Paper No. 410 - Flow ofFluids through Valves, Fittings and Pipe CRANE Engineering Division, 1985 .. Crane Co.

8.S Nuclear Plant Engineerina Desk Top Procedure EDP..o32 Rev. 1.. Instrument Loop Uncertainty and Setpoint calculations 8.6 USNRC Regulatory Guide I.I0S Rev. 1 - Instrument Setpoints EC-39605, Revise Standard 1S-09 Methodology 8.8 EN-DC-200, Revision 0, I&C Uncertainties I Setpoint Calculations & Detenninations 8.9 TSTF-493, Revision 4, Technical Specifications Task Force Traveler - Clarify Application of Setpoint Methodology for LSSS Functions 8.10 ECH-NE-08-000l5, Revision 0, Drift Analysis Design Guide 8.11 05-S-02-VI-3, Revision 107, Earthquake Off-Nonnal Event Procedure

STANDARD NO.: GGNS-JS-09 REVISION: 1 ,

DATE: '/7/~POO GRAND GULF NUCLEAR STATION INSTRUMENTATION AND CONTROL STANDARD METHODOLOGY FOR THE GENERATION OF mSTRUMENTLOOPUNCERTAJNTY

& SETPOINT CALCULATIONS

- SAFETY RELATED -

GRAND GULF NUCLEAR STATION NUCLEAR PLANT ENGINEERING REVIEW AND APPROVAL SHEET STANDARD NO.: .....;::G~G~N~S.J.:.;:S:..:*O:.:;9 REVISION; 1 __

STANDARD TITLE: Methodology for the Generation of Instrument Loop Uncertainty & SetDOint Calculations

---

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

This document specifies items related to nuclear safety YES [ X] NO [ ]

This document contains Special Requirements YES [ ] NO [X]

originated, verified, reviewed or waived and approved as noted below:

O~G~Mffi~:~~~~~~~~~~~~~~_DME: 7J~~ I VERIFIED BY; -------=~..:_.~~===---__s=:~---DATE: 11&/O<::J REVIEWED BY: ~~~~~~~~~~~~~~~~-DATE: 1-6-00 DESIGN ENGINEERING SECTION REVIEW WAIVED BY DATE ELECTRICAUI&C MECHANICAUCIVIL ENGINEERING PROGRAMS SAFETY ANALYSIS ANII: _..;.;.~+i4I....l.._ DATE: _

~(Insert N/A if not applicable) ,

APPROVED BY: ;JIJ~

~il1TtieMt:..an-ag-e-r -~-------

DATE: I hLDO r*

fORM 32) .), Revision 8

STANDARD NO.: GGNS*JS-09 REVISION: 1 I PAGE 1 of 32 REVISION STATUS SHEET STANDARD REVISION

SUMMARY

REVISION ISSUE DATE DESCRIPTION o 03/23/93 Issued for use I General revision 1/1/()t) & incorporate SCN98/0001 PAGE REVISION STATUS PAGE NO. REVISION PAGE NO. REVISION 01 1 11 1 02 1 18 1 03 1 19 1 04 1 20 1 05 1 21 1 06 1 22 1 07 1 23 1 08 1 24 1 09 1 25 1 10 1 26 1 11 I 27 1 12 I 28 I 13 1 29 1 14 1 30 1 15 1 31 1 16 1 32 1 APPENDIX I A'ITACHMENT REVISION STATUS APPENDIX NO. REVISION AITACHMENT NO. REVISION A 1 1 1 B 1 C 0 D 0

STANDARD NO.: GGNS-JS-09 REVISION: 1 f PAGE 2 of 32 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE... ..... ..... ....... ........... ... ....... .. ......... ........ ... ......... ........ 3 2.0 SCOPE AND ORGANIZATION.................................................. ... 3 3.0 DEFINITIONS AND TERMINOLOGy................ 4 4.0 SAFETY RELATED SETPOINT CALCULATIONS (TECH. SPEC.) 11 5.0 SAFETY RELATED SETPOINT CALCULAnONS (NON-TECH. SPEC.) .. 19 6.0 INSTRUMENT INDICATION UNCERTAlNTY CALCULATIONS 26 7.0 METHODS FORlNCREASINGCALCULATEDMARGINS 31

8.0 REFERENCES

........................................................................... 32 APPENDICES Appendix A - SPURIOUS TRIP AND LER AVOIDANCE ANALYSIS Appendix B - PROCESS MEASUREMENT UNCERTAINTIES Appendix C - INSULATION RESISTANCE EFFECTS Appendix 0 - ACRONYMS AND ABBREVIAnONS

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 3 of 32 SECTION 1: PURPOSE The purpose ofthis engineering standard is to provide the user with the basic tenninology and methodology to be employed in the generation of instrument loop uncertainty and setpoint calculations at GONS. This standard~ when used in conjunction with Desktop Procedure EDP-032, will promote uniformity in instrument loop uncertainty and setpoint calculations generated by Design Engineering.

SECTION 2: SCOPE and ORGANIZATION This standard is based on ISA RP67.04 Part II, 1994, - Methodologies for the Detennination of Setpoints for Nuclear Safety-Related Instrumentation and NEDC 31336P-A, 1996, - General Electric Instrument Setpoint Methodology.

The topical areas listed below are discussed in the following sections ofthis document:

• Terminology to be used in the generation of instrument loop uncertainty and setpoint calculations (Section 3)

• Methodology to be used in the generation ofsetpoint calculations for Nuclear Safety-Related Instrumentation which are addressed in the GONS Technical Specifications (Section 4)

• Methodology to be used in the generation ofsetpoint calculations for Nuclear Safety-Related Instrumentation which do not form a part ofthe GONS Technical Specifications (Section 5)

• Methodology to be used in the generation of general instrument indication uncertainty calculations (Section 6)

• Methods to be used to increase calculated margins (Section 7)

• Methodology for determining the probability of Spurious Trips and the probability of occurrence of events which would result in Licensee Event Reports (Appendix A)

• Analytical techniques for detennining possible measurement uncertainty effects due to specific process variations (Appendix B)

• Analytical techniques for determining possible measurement uncertainty due to degraded loop insulation resistance (Appendix C)

STANDARD NO.: GGNS-JS-09 REVISION: ] I PAGE 4 of 32 SECTION 3: DEFINITIONS and TERMINOLOGY 3.1 General Terminology 3.1.1 Allowable Value - AV A limiting value that the trip setpoint may have when tested periodically, beyond which appropriate action shall be taken. [Ref. 8.1]

3.1.2 Analytical Limit - AL The value of the sensed process variable established as part ofthe safety analysis prior to or at the point that a desired action is to be initiated to prevent the safety process variable from reaching the associated Licensing Safety Limit. [Ref. 8.3]

3.1.3 Abnonnally Distributed Uncertainty - F A tenn used to denote uncertainties that do not have a nonnal distribution. This type of uncertainty is treated as a bias against both the positive and negative components ofamodule's uncertainty (Ref. 8.1]

3.1.4 Bias A Bias is a component of uncertainty that consistently has the same algebraic sign, and is expressed as an estimated limit ofmor. [Ref. 8.1)

Positive Bias - M A Positive Bias is a known error in process measurement that consistently has a known positive value with respect to the process variable.

Negative Bias - L A Negative Bias is a known error in process measurement that consistently bas a known negative value with respect to the process variable.

Bias tenns should only be accounted for if the bias acts in a conservative direction with respect to the calculated variable.

STANDARD NO.: GGNS*JS-09 REVISION: J I PAGE 5 of 32 3.1.5 Design Basis Event - DBE The limiting abnonnal transient or an accident which is analyzed using the analytical limit value for the setpoint to detennine the bounding value of a process variable.

[Ref. 8.3J 3.1.6 Licensee Event Report - LER A report which must be filed with,the NRC bythe,..utility when a Tech. Spec. limit is known to be exceeded, as required by IOCFRSO.73. [Ref. 8.3]

3.1.7 Licensing Safety Limit - LSL The limit on a safety process variable that is established by licensing requirements to provide conservative protection for the integrity ofphysical barriers that guard against uncontrolled release ofradioactivity. [Ref. 8.3]

3.1.8 Limiting Nonnal Operating Transient - XT The most severe transient event affecting a process variable during nonna! operation for which trip initiation is to be avoided. [Ref. 8.3]

3.1.9 Process Limit - PL The Process Limit is the limiting process value (maximum or minimum) required for proPer system operation. (e.g. pwnp net positive suction head and min. flow requirements may be loop Process Limits) 3.1.10 ~

Span is defined as the algebraic difference between the upper and lower values of a calibrated range. [Ref. 8.1]

3.1.11 Trip Environment The environment that exists up to and including the time when the instrument channel perfonns its initial safety (trip) function during an event. [Ret: 8.3]

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 6 of 32 3.1.12 Upper Range Limit - URL Upper Range Limit is defined as the maximum value ofthe process variable that a device can accurately measure. [Ref. 8.2]

3.2 Device Specific Random Uncertainty Terms

.3.2.1 .Device Uncertainty - Ax The Device Uncertainty is defined as the square root sum ofthe squares (SRSS) ofall the applicable individual components ofuncertainty associated with a given device.

(i.e. the SRSS ofthe uncertainty effects listed in Sections 3.2.2 - 3.2.9) [Ref. 8.3]

3.2.2 Reference Accuracy - RA Reference Accuracy (or Accuracy Rating) is a number or quantity that defmes a limit that errors will not exceed when a device is used under specified operating conditions.

Reference accuracy includes, as applicable, the combined effects of: deadband, hysteresis, linearity and/or repeatability. [Ref. 8.2]

Deadband Deadband is defined as the range through which an input can be varied without initiating an observable response at the output (usually expressed in percent ofspan).

[Ref. 8.2]

Hysteresis Hysteresis is defined as that property of an element evidenced by the dependence of the value ofthe output, for a given excursion ofthe input, upon the history ofprior excmsions and the direction of the current transverse. [Ref. 8.2]

Linearity Linearity is defined as the maximum deviation of the calibration curve (average ofthe upscale and downscale readings) from a straight line which is so positioned as to minimize the maximum deviation. [Ret: 8.2]

STANDARD NO.: GGNS-JS..o9 REVISION: ) I PAGE 7 of 32 Repeatability Repeatability is defined as the closeness of agreement among a number of consecutive measurements ofthe output for the same value ofthe input Wlder the same operating conditions approaching from the same direction, for full nmge transverses. [Ref. 8.2]

3.2.3 Temperature Effects -lE Temperature Effects are defined as the changes in the input/output relationship of a device due to fluctuations in the ambient temperature to which the device is exposed.

This effect may only be assumed to be applicable for temperature variations outside the assumed nonnal calibration temperature range of 65°P to 900 P (Le. from the minimwn expected ambient temperature to 65°F or from 900 P up to the maximum expected ambient temperature). The effects oftemperature variations within the calibration temperature band must be addressed under Temperature Drift effects (See Section 3.2.12). [Ret 8.3]

3.2.4 Humidity Effects - HE

/

Humidity Effects are defined as the changes in the input/output relationship ofa device due to fluctuations in the ambient hwnidity levels to which the device is exposed. [Ref. 8.3]

3.2.5 Seismic Effects - SE Seismic Effects are defined as the changes in the input/output relationship ofa device due to the effects of seismic vibrations during or after a seismic event. [Ref. 8.3]

3.2.6 Radiation Effects - RE Radiation Effects are defined as the changes in the input/output relationship ofa device due to radiation exposure considering both the dose rate and total dose:

[Ref. 8.3]

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 8 of 32 3.2.7 Power Supply Effects - PS Power Supply Effects are defmed as the changes in the input/output relationship of a device due to fluctuations in the power supply feeding the device. Voltage and/or frequency fluctuations may result in Power Supply Effects. (Ref. 8.1]

3.2.8 Static Pressure Effect - SPE

-Static Pressure Effect is defmed as the WlCertainty introduced in ..differential pressure instruments which are calibrated at a static pressure that is different from the nonnal operating pressure. SPE may affect both the span and zero of the instrument.

3.2.9 Overpressure Effects - OVP Overpressure Effects are defmed as the changes in the input/output relationship of a pressure sensing device after exposure to process pressure in excess of its specified Upper Range Limit.

3.2.10 Device Drift - DR An undesired change in output over a Period oftime where change is unrelated to the input, environment or load. (Ref. 8.1]

Uncertainty due to drift is dePendent on the calibration frequency ofthe device.

3.2.11 Radiation Drift - RD Radiation Drift is defined as the time dependant change in the input/output relationship ofa device that can be directly related to radiation exposure.

3.2.12 Temperature Drift - TO Temperature Drift is defined as the change in the input/output relationship ofa device due to ambient temperature swings over a calibration period. I

STANDARD NO.: GGNS-JS-09 REVISION: I I PAGE 9 of 32 Temperature Drift effects may be assumed to be applicable only over the expected range oftemperature during calibration (typically 65°F to 90°F). The possible uncertainty due to temPeratlu'e variations outside this range is addressed under Temperature Effects. (See Section 3.2.3) [Ref. 8.3]

3.2.13 Measurement and Test Equipment Effects - MTE Measurement and Test Equipment Effects are defined as those uncertainties introduced into a .device as aresult of.the uncertainties .associated with the' equipment used to calibrate the device.

3.3 Loop Specific Random Uncertainty Terms 3.3.1 Loop Device Uncertainty - At The Loop Device Uncertainty is defmed as the square root sum ofthe squares (SRSS) of all the individual Device Uncertainty tenns for a given instrument loop. (Ref: 8.3]

3.3.2 Loop Calibration Uncertainty - CL The Loop Calibration Uncertainty is defined as the SRSS ofall the Measurement and Test Equipment effects that may be incurred during calibration of each ofthe devices in a given loop. [Ref. 8.3]

3.3.3 Loop Drift - D.

The Loop Drift is defined as the SRSS of the all the drift terms for each of the loop devices. The Loop Drift includes (as applicable) allowances for Device Drift, Temperature Drift, and Radiation Drift for each device in the loop. [Ref. 8.3]

3.3.4 Process Measurement Uncertainty - PM Process Measurement Uncertainties are those uncertainties that may be introduced in an instnunent loop due to limitations in modeling the physical system; or more commonly, those uncertainties introduced in an instnunent loop due to fluctuations in the process for which the loop instnunentation cannot automatically compensate.

(See Appendix B)

STANDARD NO.: GGNS-JS-09 REV1SION: 1 I PAGE 10 of 32 3.3.5 Primary Element Uncertainty - PE Primary Element Uncertainty is defined as the uncertainty introduced in an instrument loop due to the uncertainties associated with the loop's primary measuring device. Primary Element Uncertainty applies to the uncertainty associated with flow elements~ elbow taps, and similar devices which may not typically be considered instruments.

.3.3.6 Insulation Resistance Effects - IR Insulation Resistance Effects are defmed as those uncertainties introduced in an instrument loop due to changes in the insulation resistance properties of the cables, penetrations, splices and tenninations within the loop. Insulation Resistance Effects may be bias type errors as opposed to random uncertainties depending on the type of instrument loop under consideration. (See Appendix C)

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE IJ of 32 SECTION 4: SAFETY RELATED SETPOINT CALCULAnONS (Tech. Spec.)

As stated in Regulatory Guide 1.105, the accuracy of instrument setpoints should be equal to or better than the accuracy assumed in the safety analysis. Therefore, Safety Related Setpoint Calculations employ norntal distribution uncertainty data specified to at least 2 standard deviations (20), or 950/0 confidence level.

To ensure the calculated setpoint and associated calculated margins are capable of accommodating the worst case uncertainty, the trip environment for the postulated design basis event should bedetennined. Once these worst case*environmental effects have been detennined, the appropriate uncertainty values can be included in the calculation to account for any environmental effects to the instromentation or the process variable.

Using the available uncertainty data, the following general steps (outlined in Sections 4.1 - 4.5) should be used to generate an appropriate loop Allowable Value and Nominal Trip Setpoint.

• Calculate the Loop Uncertainty (LV) by computing the SRSS ofthe Loop Device Uncertainty (AJ, the Loop Calibration Uncertainty (CJ, the Process Measurement Uncertainty (PM), the Primary Element Uncertainty (PE), and the loop Insulation Resistance Effects (IR).

• Calculate the Loop Drift (DJ by computing the SRSS ofthe Device Drift (DR), the TemPerature Drift (TD), and the Radiation Drift (RD) for each loop instrument as applicable.

• Calculate the Total Loop Uncertainty (TLU) by summing the Loop Uncertainty and the Loop Drift.

• For process variables that increase to the Analytical Limit (AL), calculate the loop Allowable Value (AV) by subtracting the Loop Uncertainty from the Analytical Limit For process variables that decrease to the Analytical Limit, calculate the loop Allowable Value by summing the value ofthe Loop Uncertainty and the Analytical Limit.

• For process variables that increase to the Analytical Limit (AL), calculate the loop Nominal Trip Setpoint (NTSP) by subtracting the value of the Total Loop Uncertainty from the Analytical Limit. For process variables that decrease to the Analytical Limit, calculate the loop Nominal Trip Setpoint by summing the value ofthe Total Loop Uncertainty and the Analytical Limit.

Once the loop Allowable Value and Nominal Trip Setpoint have been established, Spurious Trip and LER Avoidance analysis must be performed as described in Section 4.6 for the field setpoint.

These analyses will demonstrate the adequacy ofthe margins associated with the setpoint.

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 12 of 32 4.1 Calculation of Loop Uncertainty - LU The Loop Uncertainty (LU), which defines the margin between the loop Analytical Limit and Allowable Value, is given by the equation:

Where the variables At, eL, PM, PE, and IR are detennined as follows:

4.1.1 Loop Device Uncertainty - AL For a loop consisting of instruments A, B, C, ... X, the loop device uncertainty is given by the equation:

Where each of the individual device uncertainties AA' As, Ac, ... Ax are fonned from the SRSS ofthe components of uncertainty listed in Sections 3.2.2 - 3.2.9 (as applicable).

Where:

RAx = Reference Accmacy ofdevice X TEx = Temperature Effects for device X HEx = Humidity Effects for device X SEx = Seismic Effects for device X REx = Radiation Effects for device X PS x = Power Supply Effects for device X SPEx = Static Pressure Effects for device X OVPx = Overpressure Effects for device X

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 13 of 32 4.1.2 Loop Calibration Uncertainty - CL For a loop consisting ofinstnunents A, B, C, ... X, the loop calibration uncertainty is given by the equation:

Where:

MTEA = SRSS ofthe measurement and test equipment effects incurred during calibration of instnunent A MTEs = SRSS of the measurement and test equipment effects incurred dwing calibration of instnunent B MTEx = SRSS ofthe measurement and test equipment effects incurred during calibration of instnunent X Since the uncertainties associated with specific pieces offield measurement/test equipment are often difficult to obtain, an alternate (and typically more conservative) approach may be used to determine the Loop Calibration Uncertainty.

This alternate approach is based on the asswnption that the Measurement and Test Equipment effects associated with each loop device are equal to the Reference Accuracy of that device (i.e. MTEx = RAJ. Thus, the Loop Calibration Uncertainty may be expressed as:

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 14 of 32 4.1.3 Process Measmement Uncertainty - PM Any loop uncertainty that may be attributable to effects similar to those described in Appendix B must be detennined by appropriate analytical techniques and accounted for under Process Measurement Uncertainty.

4. t.4 Primary Element Uncertainty - PE Ifthe instrument loop has a device which is.essential to.the measurement of the process variable, other than those devices previously addressed in the calculation of the Loop Device Uncertainty (AJ, the base uncertainty associated with this device must be determined and accounted for under Primary Element Uncertainty.

4.1.5 Insulation Resistance Effects - IR If the instrument loop cable, penetrations, splices or terminal blocks may be exposed to harsh environments at any time before the instrumentation is to perform its trip function, the possible effects ofdegraded insulation resistance must be detennined as in Appendix C and accounted for under Insulation Resistance Effects.

Note, the basic equation for the Loop Uncertainty (given below) assumes all the variables in the equation are random in nature and are specified to two standard deviations (20).

Basic Loop Uncertainty Equation:

If some or all ofthe variables are known to a higher level ofconfidence (e.g. three standard deviations, 30), the basic equation may be modified to produce a Loop Uncertainty normalized to two standard deviations (if desired) by dividing each variable by its associated standard deviation (n) and then multiplying the total equation by 2 as shown below. [Ret: 8.3J LU = +/-2 (-AnL)2 +(c- n ,)2 + (PM)2 t

n

+ (PE)2 n

+ (IR)2 n

If one or more ofthe variables is known to be a conservative Bias as opposed to a random uncertainty t those variables should not be included under the radical and must simply be added to, or subtracted from, the SRSS ofthe remaining variables to fonn the Loop Uncertainty.

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 15 of 32 4.2 Calculation of Loop Drift* DL For a loop consisting of instruments A, B, C, ... X, the loop drift is given by the equation:

Where:

DRA =the Device Drift associated with instrwnent A IDA = the Temperature Drift Effect for instrument A RDA = the Radiation Drift Effect for instnunent A DRx = the Device Drift associated with instrument X TD x = the Temperature Drift Effect for instrument X RDx = the Radiation Drift Effect for instnunent X Since the Device Drift (DR) is directly related to the length ofthe calibration period, it may be necessary to scale the vendor supplied drift specification to accommodate the calibration interval.

Conservatively, this may be accomplished by multiplying the given drift specification by the ratio ofthe desired calibration interval to the supplied drift specification interval.

Device Drift should only be scaled when the supplied drift specification interval is less than the calibration interval.

The Device Drift for all applicable loop instrwnents must be valid (scaled ifnecessary) for the maximum calibration interval allowed by the GGNS Technical Specifications.

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 16 of 32 4.3 Calculation of Total Loop Uncertainty - TLU The Total Loop Uncertainty (TLU), which defines the margin between the loop Analytical Limit and the Nominal Trip Setpoint, is given by the equation:

TLU = LU +DL 4.4 Calculation of Loop Allowable Value - AV Using the existing documented Analytical Limit and the Loop Uncertainty calculated as shown in Section 4.1 :

The loop Allowable Value for a process variable that increases to the Analytical Limit is given by the equation:

AV=AL-ILUI An~ the loop Allowable Value for a process variable that decreases to the Analytical Limit is given by the equation:

AV=AL+!LU\

4.5 Calculation of Loop Nominal Trip Setpoint - NTSP Using the existing documented Analytical Limit and the Total Loop Uncertainty calculated as shown in Section 4.3:

The loop Nominal Trip Setpoint for a process variable that increases to the Analytical limit is given by the equation:

NTSP = AL -ITLUI And, the loop Nominal Trip Setpoint for a process variable that decreases to the Analytical Limit is given by the equation:

NTSP =AL + !TLUI

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 17 of 32 4.6 Spurious Trip and LER Avoidance Analysis A Spurious Trip and LER Avoidance Analysis must be performed as described in Appendix A to demonstrate the acceptability ofthe setpoint margins. These analyses must be performed for the setpoint that is employed in the field. These analyses are not required for calculated setpoints that are not to be implemented in the field.

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 18 of 32 TECHNICAL SPECIFICATION TRIP SETPOINT

- COMPONENTS OF UNCERTAINTY -

ANALYTICALLThfiT-AL LOOP DEVICE UNCERTAINTY - AL H

LOOP CALIBRATION UNCERTAINTY - CL

~~

LU PROCESS MEASUREMENT UNCERTAINTY - PM TLU 'r a

PRIMARY ELEMENT UNCERTAINTY - PE INSULATION RESISTANCE EFFECTS - IR ALLOWABLE VALUE - AV ., .. l' DL - LOOP DRIFT NOMINAL TRIP SETPOINT .. NTSP " ,,.

FIGURE 1: Tech. Spec. Trip SetpoiDt Uncertainty Breakdown

STANDARD NO.: GGNS-J8-09 REVISION: 1 I PAGE 19 of 32 SECTION 5: SAFETY RELATED SETPOINT CALCULAnONS (Non-Tech Spec.)

As with the methodology presented in Section 4, Non-Tech. Spec. setpoint calculations employ nonnal distribution uncertainty data specified to at least 2 standard deviations (20) which are applicable to the worst case environmental conditions assumed for the trip environment.

Non-Tech. Spec. setpoint calculations, however, differ in methodology from Tech. Spec.

setpoint calculations in that no Analytical Limit is applicable and thus no Allowable Value can be computed. Non-Tech. Spec. setpoint calculations simply add to (or subtract from) the

-associated Prooess~Limit the value ofthe Total Loop Uncertainty* to detenninethe*Nominal Trip Setpoint.

The following general steps (outlined in Sections 5.1 - 5.4) should be used to generate an appropriate Nominal Trip Setpoint for Non-Tech. Spec. variables.

• Calculate the Loop Uncertainty (LV) by computing the SRSS ofthe Loop Device Uncertainty (AJ, the Loop Calibration Uncertainty (CJ, the Process Measurement Uncertainty (PM), the Primary Element Uncertainty (PE), and the loop Insulation Resistance Effects OR).

• Calculate the Loop Drift (Dt ) by computing the SRSS ofthe Device Drift (DR), the Temperature Drift (TD), and the Radiation Drift (RD) for each loop instrument as applicable.

• Calculate the Total Loop Uncertainty (TLU) by summing the Loop Uncertainty and the Loop Drift.

• For process variables that increase to the Process Limit (PL), calculate the Loop Nominal Trip Setpoint (NTSP) by subtracting the value ofthe Total Loop Uncertainty from the Process Limit. For process variables that decrease to the Process Limit, calculate the Loop Nominal Trip Setpoint by summing the value ofthe Total Loop Uncertainty and the Process Limit.

Once the Nominal Trip Setpoint has been established a Spurious Trip analysis as described in Section 5.5 must be performed for the field setpoint. This analysis will demonstrate the adequacy ofthe margin associated with the setpoint.

STANDARD NO.: GGNS-J8-09 REVISION: 1 I PAGE 20 of 32 5.1 Calculation of Loop Uncertainty .. LU The Loop Uncertainty (LU) is defined by the equation:

Where the variables At, Cu PM, PE, and IR are detennined as follows:

5.1.1 Loop Device Uncertainty .. At For a loop consisting of instruments A, B, C, ... X, the loop device uncertainty is given by the equation:

Where each ofthe individual device uncertainties AM AB, Ac, ... Ax are formed from the SRSS ofthe components of uncertainty listed in Sections 3.2.2 .. 3.2.9 (as applicable).

Where:

RAx = Reference Accuracy of device X TEx = Temperature Effects for device X HEx = Humidity Effects for device X SEx = Seismic Effects for device X REx = Radiation Effects for device X PSx = Power Supply Effects for device X SPEx = Static Pressure Effects for device X OVPx = Overpressure Effects for device X

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 21 of 32 5.1.2 Loop Calibration Uncertainty - CL For a loop consisting of instruments A, B, C, ... X, the loop calibration uncertainty is given by the equation:

Where:

MTEA = SRSS ofthe measmement and test equipment effects incurred during calibration of instrument A MTEs = SRSS of the measurement and test equipment effects incurred during calibration of instrument B MTEx = SRSS ofthe measurement and test equipment effects incurred during calibration of instrument X Since the uncertainties associated with specific pieces offield measurementltest equipment are often difficult to obtain, an alternate (and typically more conservative) approach may be used to detennine the Loop Calibration Uncertainty.

This alternate approach is based on the assumption that the Measurement and Test Equipment effects associated with each loop device are equal to the Reference Accuracy of that device (Le. MTEx = RAx). Thus, the Loop Calibration Uncertainty may be expressed as:

STANDARD NO.: GGNS-JS-09 REVISION: I t PAGE 22 of 32 5.1.3 Process Measurement Uncertainty - PM Any loop uncertainty that may be attributable to effects similar to those described in Appendix B must be determined by appropriate analytical techniques and accounted for under Process Measurement Uncertainty.

5.1.4 Primary Element Uncertainty - PE

.. lfthe.instrument loop.has a device _which is. essential.to .the.measurement ofthe process variable, other than those devices previously addressed in the calculation of the Loop Device Uncertainty (AL), the base uncertainty associated with this device must be determined and accounted for under Primary Element Uncertainty.

5.1.5 Insulation Resistance Effects - IR Ifthe instrument loop cable, penetrationst splices or tenninal blocks may be exposed to harsh environments at any time before the instrumentation is to perfonn its trip function, the possible effects of degraded insulation resistance must be detennined as in Appendix C and accounted for under Insulation Resistance Effects.

Notet the basic equation for the Loop Uncertainty (given below) assumes all the variables in the equation are random in nature and are specified to two standard deviations (20).

Basic Loop Uncertainty Equation:

Ifsome or all ofthe variables are known to a higher level ofconfidence (e.g. three standard deviations, 30), the basic equation may be modified to produce a Loop Uncertainty nonnalized to two standard deviations (ifdesired) by dividing each variable by its associated standard deviation (n) and then multiplying the total equation by 2 as shown below. [Ref: 8.3]

_ (A- I.)2 + (C- L)2 + (PM)2 LU -+/-2 - + (PE)2

- + (IR)2 n n n n n If one or more ofthe variables is known to be a conservative Bias as opposed to a random uncertainty, those variables should not be included under the radical and must simply be added to, or subtracted from, the SRSS ofthe remaining variables to form the Loop Uncertainty.

STANDARD NO.: GGNS-JS-09 REVISION: I I PAGE 23 of 32 5.2 Calculation of Loop Drift - DL For a loop consisting of instruments A, B, C, ... X, the loop drift is given by the equation:

Where:

DRA = the Device Drift associated with instrument A TOA = the Temperature Drift Effect for instrument A RDA = the Radiation Drift Effect for instrument A DRx = the Device Drift associated with instrument X TDx = the Temperature Drift Effect for instrument X RDx = the Radiation Drift Effect for instrwnent X Since the Device Drift (DR) is directly related to the length ofthe calibration period, it may be necessary to scale the vendor supplied drift specification to accommodate the calibration interval.

Conservatively, this may be accomplished by multiplying the given drift specification by the ratio ofthe desired calibration interval to the supplied drift specification interval.

Device Drift should only be scaled when the supplied drift specification interval is less than the calibration interval.

The Device Drift for all applicable loop instruments must be valid (scaled if necessary) for the maximum calibration interval allowed for the instrument loop.

STANDARD NO.: GGNS-JS-09 REVISION: t I PAGE 24 of 32 5.3 Calculation of Total Loop Uncertainty - TLU The Total Loop Uncertainty (TLU), which defines the margin between the loop Process Limit and the Nominal Trip Setpoint, is given by the equation:

TLU=LU +Df*

5.4 Calculation of Loop Nominal Trip Setpoint - NTSP

• • Using the Process Limit-derived from existing docwnentation *and the Total Loop Uncertainty calculated as shown in Section 5.3:

The loop Nominal Trip Setpoint for a process variable that increases to the Process Limit is given by the equation:

NTSP =PL -ITLUI And, the loop Nominal Trip Setpoint for a process variable that decreases to the Process Limit is given by the equation:

NTSP = PL + ITLUI 5.5 Spurious Trip Analysis A Spurious Trip Analysis must be performed as described in Appendix A to demonstrate the acceptability ofthe setpoint margins. This analysis must be perfonned for the setpoint that is employed in the field; but is not required for calculated setpoints that are not to be implemented in the field.

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 25 of 32 NON-TECHNICAL SPECIFICATION TRIP SETPOINT

-CO~ONENTSOFUNCERTAmTY-PROCESS LIMIT - PL LOOP DEVICE UNCERTAINTY - At LOOP CALIBRATION UNCERTAINTY - CL LU PROCESS MEASUREMENT UNCERTAINTY - PM TLU PRIMARY ELEMENT UNCERTAINTY - PE

.. ~

INSULATION RESISTANCE EFFECTS - IR DL - LOOP DRIFT NOMINAL TRIP SETPOINT .. NTSP ." ."

FIGURE 2: NOD-T~h. Spec. Trip Setpoint UneertaiDty Breakdown

STANDARD NO.: GGNS-JS-09 REVISION: ] I PAGE 26 of 32 SECTION 6: INSTRillvfENT INDICAnON UNCERTAINTY CALCULATIONS As with the methodologies presented in Sections 4 & 5, Instrument Indication Uncertainty Calculations employ Donnal distribution uncertainty data specified to at least 2 standard deviations (20') which are applicable to the worst case environmental conditions postulated for the instrwnent location. For instrwnentation used to monitor Reg. Guide 1.97 variables, the worst case environmental effects specific to the instrwnent location associated with the Design Basis Accident are to be used in the calculation.

Indication Uncertainty Calculations differ in methodology from setpoint calculations in that the Loop Drifl-isnot calculated separately from the Loop Uncertainty. -Instead the Loop Drift is included with the other random uncertainty components under the radical to fonn the Total Random Loop Uncertainty (RLU).

Another important difference between indication uncertainty calculations and setpoint calculations is that indication uncertainty calculations must address the man-machine interface associated with the indicator. For indicators with linear scales, this possible source of uncertainty is assigned a value equal to 1/2 the value ofthe indicator's minor scale division.

This allowance accounts for the effects of parallax and the mental interpolation required ofthe operator and is tenned the 'Readability ofthe Indicator' (RI).

For loops using indicators with non-linear scales (i.e. square-law or log scales) the RI tenn should be calculated based on decades or other appropriate ranges rather than process units to alleviate the inequity between the size ofthe minor divisions at the upper an lower extremes of the indicator's scale. Note, 'Readability' is not applicable for recorders and digital readout devices.

The following general steps (outlined in Sections 6.1 - 6.3) should be used to detennine the worst case instrument indication uncertainty for a given loop:

• Calculate the Readability term (RI) by taking 1/2 the value of the indicator's minor scale division (or another appropriate value estimated for indicators with non-linear scales).

• Calculate the Random Loop Uncertainty (RLU) by computing the SRSS ofthe Loop Device Uncertainty (AJ, the Loop Calibration Uncertainty (CJ, the Loop Drift (OJ, the Process Measurement Uncertainty (PM), the Primary Element Uncertainty (PE), and the loop Insulation Resistance Effects (lR).

• Calculate the Total Loop Uncertainty (TLU) by combining the Random Loop Uncertainty, Readability and any conservative bias terms.

STANDARD NO.: GGNS-JS-09 REVISION: ] I PAGE 27 of 32 6.1 Calculation of Readability - RI For indicators with linear scales the 'Readability' ofthe Indicator is:

RI = +/- ~ (minor indicator scale division) 6.2 Calculation ofRandom Loop Uncertainty - RLU The Random Loop Uncertainty (RLU) is defined by the equation:

Where the variables AL , Ct, DL , PM, PE, and IR are determined as follows:

6.2.1 Loop Device Uncertainty - AL For a loop consisting of instruments A, B, C, ... X, the loop device uncertainty is given by the equation:

Where each ofthe individual device uncertainties AM As, Ac, ... Ax are formed from the SRSS ofthe components of uncertainty listed in Sections 3.2.2 - 3.2.9 (as applicable).

Where:

RAx = Reference Accuracy of device X TEx =Temperature Effects for device X HEx = Humidity Effects for device X SEx = Seismic Effects for device X REx = Radiation Effects for device X PSx = Power Supply Effects for device X SPEx = Static Pressure Effects for device X OVPx =Overpressure Effects for device X

STANDARD NO.: GGNS-JS-09 REVISION: ] I PAGE 28 of 32 6.2.2 Loop Calibration Uncertainty - CL For a loop consisting of instruments A, B, C, ... X, the loop calibration uncertainty is given by the equation:

Where:

MTEA = SRSS ofthe measurement and test equipment effects incurred during calibration of instrument A MTEB = SRSS of the measurement and test equipment effects incurred during calibration of instrument B MTEx = SRSS ofthe measurement and test equipment effects incurred during calibration ofinstrument X

. Since the wtcertainties associated with specific pieces offield measurement/test equipment are often difficult to obtain, an alternate (and typically more conservative) approach may be used to detennine the Loop Calibration Uncertainty.

This alternate approach is based on the assumption that the Measurement and Test Equipment effects associated with each loop device are equal to the Reference Accuracy ofthat device (i.e. MTEx = RAx). Thus, the Loop Calibration Uncertainty may be expressed as:

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 29 of 32 6.2.3 Calculation of Loop Drift - DL For a loop consisting of instruments A, B, C, ... X, the loop drift is given by the equation:

Where:

DRA = the Device Drift associated with instrument A TDA = the Temperature Drift Effect for instrument A RD A = the Radiation Drift Effect for instrument A DRx = the Device Drift associated with instnunent X TDx = the Temperature Drift Effect for instrument X RDx = the Radiation Drift Effect for instrument X Since the Device Drift (DR) is directly related to the length ofthe calibration period, it may be necessary to scale the vendor supplied drift specification to accommodate the calibration interval.

Conservatively, this may be accomplished by multiplying the given drift specification by the ratio ofthe desired calibration interval to the supplied drift specification interval.

Device Drift should only be scaled when the supplied drift specification interval is less than the calibration interval.

STANDARD NO.: GGNS-JS*09 REVISION: 1 I PAGE 30 of 32 6.2.4 Process Measurement Uncertainty - PM Any loop uncertainty that may be attributable to effects similar to those described in Appendix 8 must be accounted for under Process Measurement Uncertainty.

6.2.5 Primary Element Uncertainty .. PE Ifthe instrument loop has a device which is essential to the measurement ofthe process variable, other than those devices previously addressed in the calculation of the Loop Device Uncertainty (AJ, the base Wlcertainty associated with this device must be accounted for under Primary Element Uncertainty.

6.2.6 Insulation Resistance Effects - IR Ifthe instrument loop cable, penetrations, splices or tenninal blocks may be exposed to harsh environments at any time before the instrumentation is to perfhnn its trip function, the possible effects ofdegraded insulation resistance must be detennined as in Appendix C and accounted for under Insulation Resistance Effects.

Note, the basic equation for the Random Loop Uncertainty (given below) assumes all the variables in the equation are random in nature and are specified to two standard deviations (20).

Basic Random Loop Uncertainty Equation:

If some or all ofthe variables are known to a higher level ofconfidence (e.g. three standard deviations, 30), the basic equation may be modified to produce a Random Loop Uncertainty normalized to two standard deviations (if desired) by dividing each variable by its associated standard deviation (n) and then multiplying the total equation by 2 as shown below. {Ret: 8.3]

STANDARD NO.: GGNS*JS-09 REVISION: 1 I PAGE 31 of 32 6.3 Calculation of Total Loop Uncertainty - TLU TLU = RLU + RI + Bias SECTION 7: METHODS FOR INCREASING CALCULATED MARGINS Calculations generated using the methodology presented in this standard maY!I due to the in-depth treatment of the uncertainty tenns, generate setpoint and instrument uncertainty estimates which are more conservative than previously calculated values.

If in the generation of setPoints and loop Allowable Values, a large difference is noted between the existing and calculated valueS!l various techniques should be considered to isolate and possibly reduce these differences ifappropriate.

In certain cases, the following may be valid techniques to reduce calculated uncertainty tenns:

7.1 Review the environmental limits to reduce them as necessary to reflect only the specific event requirements for which the device is required to function.

7.2 Review the value used for Insulation Resistance Effects to ensure that it is not overly conservative 7.3 Review the Measurement & Test Equipment values used in the calculation as a tenn to be reduced, especially if the M&TE values have been assumed to be equal to the Reference Accuracy ofthe individual loop devices.

7.4 A Single-sided Distribution approach to the uncertainty may be considered, depending on the application. This approach may not be applicable to all setpoints due to the possible impact on operational margins or other system setpoints. Note, if this apProach is employ~ all data should be nonnalized for Single-Sided Distribution. With the 20' data applied to Single-Sided Distribution, the accuracy will exceed the 95% confidence level.

(See Reference 8.3) 7.5 The Total Loop Uncertainty may be reduced using the square root sum of the squares approach to combine the Loop Uncertainty and the Loop Drift. Generally t this approach should be avoided since it minimizes the margin between the loop Allowable Value and the Nominal Trip Setpoint. Values calculated using this apProach should be reviewed to ensure adequate margin exists between the Nominal Trip Setpoint and the Allowable Value.

STANDARD NO.: GGNS-JS-09 REVISION: 1 I PAGE 32 of 32 SECTION 8: REFERENCES 8.1 ISA RP67.04, Part II, 1994, Methodologies for the Detennination of Setpoints for Nuclear Safety-Related Instrumentation 8.2 Process Measurement - Instrument Engineers' Handbook Revised Edition Bela G. Liptak & Kristzta Venczel, 1982 .. Chilton Book Co., Radnor Pennsylvania 8.3 NEDC..31336P-A, 1996, General Electric Instrument Setpoint Methodology W.H. Cooley, JR., J.L. Leong, M.A. Smith, S. Wolf, - General Electric Co.

8.4 CRANE Technical Paper No. 410 - Flow of Fluids through Valves, Fittings and Pipe CRANE Engineering Division, 1985 - Crane Co.

8.5 Nuclear Plant Engineering Desk Top ProcedW'e EDP-032 Rev. 1 - Instrument Loop Uncertainty and Setpoint Calculations 8.6 USNRC Regulatory Guide 1.105 Rev. 1 .. Instrument Setpoints

STANDARD NO.: GGNS-JS-09 APPENDIX: A REVISION: 1 PAGE 1 OF 5 APPENDIX A SPURIOUS TRIP AND LER AVOIDANCE ANALYSIS

STANDARD NO.: GGNS-JS-09 APPENDIX: A REVISION: 1 PAGE 2 OF 5 INTRODUCTION The Spurious Trip and Licensee Event Report (LER) Avoidance analysis techniques that follow are used to demonstrate the acceptability offield setpoints with respect to specific operating margins.

These techniques and the associated tenninology are referenced from NEDC 31336P-~ 1996~

General Electric Instnunent Setpoint Methodology.

In both the Spurious Trip and LER Avoidance analysis, the probability that the margin of interest will not be exceeded is detennined by the area under the nonnal standard deviation curve from -00 to Z, where Z is derived by dividing the magnitude ofeach respective margin by the appropriate standard deviation.

The standard normal distribution curve is shown below with the minimwn "ZtI values for 90% and 95% probability, the acceptance criteria for LER Avoidance and Spurious Trip Avoidance respectively.

Z=1.28 Z=1.645 z

-4.5 3.5 2.5 1.5 0.5 0 0.5 1 1.5 2 2.5 3 3.5 4 4.5

~ 90% PROBABILITY

~ 95% PROBABILITY

STANDARD NO.: GGNS-JS-09 APPENDIX: A REVISION: I PAGE30F5 1.0 SPURIOUS TRIP ANALYSIS Spurious Trip analysis is perfonned to demonstrate the acceptability ofthe margin between a Nominal Trip Setpoint and the value of the limiting process transient variation associated with the setpoint. Ifthe setpoint is acceptable, there should be at least a 95% probability that this margin will not be exceeded and no spurious trip will occur.

The probability ofavoiding spurious trips for a single channel is detennined by calculating a value liZ" as shown below. This Z value is then used to detennine the area under the standard normal distribution curve from -00 to Z using standard statistical tables. Note, any Z ~ 1.645 will meet the acceptance criteria of 95% spurious trip avoidance.

A Spurious Trip analysis should be performed for all field setpoints validated by calculation and may be perfonned for calculated setpoints that are not to be employed in the field.

Discussion of Variables:

NTSP - Nominal Trip Setpoint XT - Limiting Operating Transient Variation X T = Xa + T + Tc, ifthe process variable increases to the Analytical Limit XT = Xo - T - Tc:' if the process variable decreases to the Analytical Limit Where:

Xc. = maximum. or minimum steady state operating value T = magnitude ofthe limiting transient variation Tc = modeling bias or uncertainty

STANDARD NO.: GGNS-JS-09 APPENDIX: A REVISION: 1 PAGE 4 OF 5 The limiting operating transient (XI) is typically calculated as shown; however, this value may be specifically noted in the system operating instruction. Unless justification is provided, the value ofXT should not be closer to the oPeI'ating limit than the setpoint.

The steady state operating value (XJ may be determined from the system operating instructions, Technical Specifications, design specifications or similar documentation.

The limiting transient variation (T) is typically the margin between the steady state operating value and the process setpoint, but the limiting variation may be related to some other operating limit/restriction invoked by the system operating instructions or the Technical Specification.

The modeling bias or uncertainty (Te) is typically zero when using existing documented operating restrictions. This term is used to add any margin for uncertainty when specifying the limiting transient variation based on engineering judgement.

O'N - The standard deviation associated with the limiting operating transient (O'N)' is equal to zero when the limiting operating transient is based on existing documented operating restrictions. This term is used to account for any deviation associated with the limiting operating transient when the limiting transient is based on engineering judgement.

OJ - The standard deviation associated with the loop uncertainty, denoted aj, is calculated as shown below:

Where:

n = number ofstandard deviations used in expressing the individual components of uncertainty AL Loop Device Uncertainty CL = Loop Calibration Uncertainty DL = Loop Drift PM = Process Measurement Uncertainty PE = Primary Element Uncertainty

STANDARD NO.: GGNS-JS-09 APPENDIX: A REVISION: ]

PAGE50F5 2.0 LER AVOIDANCE ANALYSIS LER Avoidance analysis is perfonned to demonstrate the acceptability ofthe margin between a loop Allowable Value and Nominal Trip Setpoint. Ifthe setpoint is acceptable. there should be at least a 9QO./c) probability that this margin will not be exceeded.

The probability of LER avoidance for a single channel is determined by calculating a value "z" as shown below. This Z value is then used to determine the area under the standard normal distribution curve from -00 to Z. Note, any Z ~ 1.28 will meet the acceptance criteria of 90% LER avoidance.

An LER Avoidance analysis should be perfonned for each field setpoint/allowable value validated by calculation and may be perfonned for calculated values that are not to be employed in the field.

z= IAV-NTSPI

!~(AI)2 +(CL)2 +(DL)2 n

Where:

AV = Allowable Value NTSP = Nominal Trip Setpoint AL Loop Device Uncertainty CL = Loop Calibration Uncertainty DL = Loop Drift n = number of standard deviations used in specifying the individual components of uncertainty

STANDARD NO.: GGNS-JS-09 APPENDIX: B REVISION: 1 PAGE 1 OF9 APPENDIXB PROCESS MEASUREMENT UNCERTAINTIES

STANDARD NO.: GGNS-JS-09 APPENDIX:B REVISION: 1 PAGE 2 OF9 INTRODUCTION Process measurement uncertainties are: those uncertainties which may be introduced in an instnunent loop due to limitations in modeling the physical system; or more commonly, those uncertainties introduced in an instrument loop due to fluctuations in the process for which the loop instrumentation can not automatically compensate.

Note, this Appendix is not intended to be an exhaustive discussion of Process Measurement Uncertainty but rather is intended only to present specific analysis techniques used to address common Wlcertainties associated with process measurement.

1.0 FLOW MEASUREMENT UNCERTAINTY - (FLUID DENSITY EFFECTS)

In systems that use differential pressure transmitters to detect flow, measurement uncertainty may be introduced by density changes in the process fluid Such variations in fluid density are generally the result oftemperature transients in the system.

As shown in the equations below, a change in the density ofthe process fluid will result in a variation of the sensed variable (OP) if the flow rate is constant. Therefore, the flow derived from the pressure measurement will not be a true representation oithe actual flow.

Q = K(A) ~ (volumetric flow rate)

V~

w = K(A)~DP(Density) (mass flow rate)

Where:

Q = Volumetric flow rate W = Mass flow rate A = Cross sectional area ofthe pipe K = Constant DP = Differential pressure measured across the orifice plate Density = Density ofthe process fluid

STANDARD NO.: GGNS-JS-09 APPENDIX: B REVISION: I PAGE30F9 By assuming Q, the volumetric flow rate ofthe system, remains constant between a base calibration condition (Density 1) and some final condition (Density 2) the measurement uncertainty due to fluid density changes may be derived as follows:

Q2=Ql K(A) DP2 =K(A) DPI Density 2 Density1 DP2 DPI

=---

Density2 Density!

Since density is the inverse of specific volume (SV), the results above may be expressed as*:

DP2 SVI

--=--

DPI SV2 Clearly, ifthe specific volwne ofthe process fluid changes between condition 1 and condition 2, the differential pressure will also change. This change in differential pressure (£\DP) is given by:

ADP = DP2 - DPI

• Since the density of water is given in the ASME Steam Tables in terms of specific volume, relating DP to specific volume is generally more convenient than relating DP to density.

STANDARD NO.: GGNS-JS-09 APPENDIX: B REVISION: 1 PAGE40F9 By expressing OP2 in terms ofOPI and substituting, the DP uncertainty can be expressed as:

Where:

OPI = Differential pressure sensed at calibration temperature (Tl)

SVI = SPeCific volume ofthe process fluid at calibration temperature (T1)

SV2 = Specific volume ofthe process fluid at any arbitrary temperature (1'2)

NOTE:

• IfSV2> SVI (1'2 > Tl): the indicated flow is less than the actual flow

• If SV2 < SVI (T2 < Tl): the indicated flow is greater than the actual flow

• If OPt is maximized, the uncertainty is maximized.

Although the results above are applicable only to volumetric flow rate; the same methodology may also be used to detennine mass flow rate density effects.

STANDARD NO.: GGNS-JS-09 APPENDIX: B REVISION: 1 PAGESOF9 2.0 LEVEL MEASUREMENT UNCERTAINTIES - (FLUID DENSITY EFFECTS)

When differential pressure transmitters are used to measure liquid level, changes in the density ofthe liquid within the vessel and/or the transmitter reference leg fluid may result in process measurement uncertainty. The following discussion addresses both open vessel and closed vessel level measurement uncertainties attributable to density variations in the process.

2.1 Open Vessel Liquid Level Measurement For measurement of liquid level in an open vessel, no reference leg considerations are applicable since both the vessel and pressure transmitter are vented to the atmosphere.

Therefore, the only density variation to be considered is that of the liquid within the vessel.

The equation below shows the relationship between the density ofthe liquid within the vessel and the pressure sensed by the transmitter in an open system.

P =H y xSG.,

OR P = H x [ density of the liqUid in the vessel ]

v density of water at ref. conditions.

Where:

P = Pressw-e sensed by the transmitter (in inches ofwater)

Hv = Height ofthe liquid in the vessel measured from the transmitter tap(in inches)

SGv Specific gravity ofthe liquid within the vessel By using the inverse relationship between density and specific volume (SV), the pressure at the transmitter may also be expressed as:

P = H x [SV of water at ref* conditiOns]

v sv of the liqUid in the vessel

STANDARD NO.: GGNS-JS-09 APPENDIX': B REVISION: ]

PAGE60F9 From the equations derived for 'pI, the pressure sensed at the transmitter, the error (L\P) resulting from density variations in the process liquid can be calculated as shown below:

OR Where:

Hv = Height ofthe liquid in the vessel measured frOm the transmitter tap (in inches)

SOy) Specific gravity ofthe process liquid at calibration temperature (Tl)

SGV2 = Specific gravity ofthe process liquid at any arbitrary temperature (1'2)

SV YI = Specific volume ofthe process liquid at calibration temperature (Tl)

SVV2 = Specific volume ofthe process liquid at any arbitrary temperature (1'2)

SVW) = Specific volume of water at some reference temperature (T3)

Ifthe process liquid is water and the reference temperature (TI) is the temperature at calibration (Tl), the equations above may be reduced to the fonn shown below:

NOTE:

• If SV V2 > SV VI (TI > Tl): the indicated level is less than the actual level

• If SVV2 < SVVI (T2 < Tl): the indicated level is ~ than the aetuallevel

STANDARD NO.: GGNS-JS-09 APPENDIX:B REVISION: 1 PAGE 70F9 2.2 Closed Vessel Liquid Level Measurement (low pressure system)

For measurement of liquid level in a closed vessel, the density variations in the transmitter reference leg fluid must be considered in conjunction with the density variations of the liquid within the vessel.

Ifthe transmitter reference leg is dry (i.e. pressurized only by the gaseous volume above the liquid in the vessel) and the vessel is at a relatively low temperature and pressure, the only significant density variation due to temperature transients will be in the vessel liquid. The density variations ofthe gaseous volume and thus the pressure variations in the reference leg under low pressure conditions are generally negligible. Therefore, the level measW'ement uncertainty due to density variations would be calculated as ifthe vessel were vented.

However, ifthe transmitter reference leg is wet (Le. pressurized by a colwnn of liquid),

both the density variations ofthe vessel liquid and the reference leg liquid could contribute to process measurement uncertainty.

The equations below show the relationship between the density ofthe process liquid, the density ofthe reference leg liquid and the differential pressure sensed by the transmitter in a low pressure closed vessel system.

OR DP = HR[Dens~tyR ]_Hv[Dens~tyJl]

Densl!yw Density,..

Where:

OP = Differential pressure sensed by the transmitter (in "We)

HR = Height ofthe liquid in the reference leg measured from the transmitter tap (in inches)

Hv Height ofthe liquid in the vessel measured from the transmitter tap (in inches)

SGR = Specific gravity ofthe liquid within the reference leg SGv == Specific gravity ofthe liquid within the vessel DensityR Density ofthe liquid within the reference leg Densityv == Density ofthe liquid within the vesse Densityw = Density of water at some reference condition

STANDARD NO.: GGNS*JS-09 APPENDIX: B REVISION: 1 PAGE80F9 By using the inverse relationship between density and specific volume (SV), the differential pressure may also be expressed as:

DP=H (SVWJ-H R SV Y (SVwJ Sv.

R Y From the equations derived for 'DP', the differential pressure sensed at the transmitter, the error (WP) introduced in the low pressure closed vessel system as a result of density variations can be calculated as shown below:

OR Where:

HR = Height of the liquid in the reference leg measured from the transmitter tap (in inches)

Hy Height of the liquid in the vessel measured from the transmitter tap (in inches)

SGRI = Specific gravity of the reference leg liquid at calibration temperature (Tl)

SGR2 = Specific gravity of the reference leg liquid at any arbitrary temperature (1'2)

SGV3 = Specific gravity ofthe vessel liquid at calibration temperature (T3)

SOY4 = Specific gravity ofthe vessel liquid at any arbitrary temperature (T4)

SV"'l = Specific volume ofthe reference leg liquid at calibration temperature (Tt SVR2 = Specific volume ofthe reference leg liquid at any arbitrary temperature (1'2)

SVYJ Specific volume ofthe process liquid at calibration temperature (T3)

SVV4 = Specific volume ofthe process liquid at any arbitrary temperature (T4)

SVw, = Specific volume of water at some reference temperature (T5)

81ANDARD NO.: GGNS-J8-09 APPENDIX:B REVISION: 1 PAGE 90F9 The preceding equations can be somewhat confusing since the reference leg liquid and the liquid within the vessel are not necessarily at the same temperature or density at any moment.

However, assuming the reference leg liquid and the liquid within the vessel are water and the reference temperature (T5) is equal to the temperature ofthe reference leg liquid at the time of calibration (Tt), the equations may be reduced to:

WP=HR[SVR1 _1]_n,,[SVR1 _SVR1 ]

SVR2 SV". SVV3 Closed vessel high pressure systems differ from low pressure closed vessel systems in that the density variations ofthe vapor region above the vessel liquid must also be considered to determine the total measurement uncertainty. A detailed discussion of this type ofsystem is not included here but is presented in Reference 8.t for a steam/water system.

The defining equation for this type of measurement is:

DP = (H R x SG R ) - (H y x SG" )- (H VAP x SG yAP )

Where:

DP = Differential pressure sensed by the transmitter (in "We)

HR = Height ofthe liquid in the reference leg measured from the transmitter tap (in inches)

Hy = Height ofthe liquid in the vessel measured from the transmitter tap (in inches)

HyAP = Height ofthe vapor region above the vessel liquid (in inches)

SGR  := Specific gravity ofthe liquid within the reference leg SGy  := Specific gravity ofthe liquid within the vessel SGVAP = Specific gravity of the vapor above the vessel liquid

STANDARD NO.: GGNS-JS-09 APPENDIX:C REVISION: 0 PAGE J OF6 APPENDIXC INSULATION RESISTANCE EFFECTS

STANDARD NO.: GGNS-JS-09 APPENDIX:C REVISION: 0 PAGE20F6 INTRODUCTION Cables, splices, connectors, tenninal blocks, and penetrations may experience a reduction in insulation resistance under conditions of high humidity and temperature associated with a high-energy line break (HELB). This reduction in insulation resistance causes an increase in leakage currents from individual conductors to ground, and from one conductor to another.

Nonnally, leakage currents are negligibly small, and may be compensated for during calibration.

However, under accident conditions, leakage currents may increase causing a significant uncertainty in measurement. This type ofsignal uncertainty, known as Insulation Resistance Effects (lR), is of great concern for instrument channels with logarithmic signals, and may be of concern for circuits with sensitive., low level, signals (e.g. current transmitters, resistive temperature devices., thennocouples, etc.).

1.0 INSULATION RESISTANCE TEST DATA LOCA simulation qualification test reports may be referenced for cable insulation resistance data. The insulation resistance data taken during LOCA simulation testing are conservative with respect to all postulated accident conditions, and are usually based on leakage currents for various cable types and measurement configurations.

Since test report data will generally be given for a test cable ofmuch shorter length than the field cable of interest, it is necessary to detennine the "ohms-foot" value ofthe insulation resistance. This factor allows the insulation resistance for a particular length offield cable to be determined.

The "ohms-foot" value is obtained by multiplying the value of insulation resistance measured for the sample cable by the length ofthe sample cable. The resistance ofvarying lengths of field cable is then detennined by dividing the ohms-foot value by the length of the field cable.

STANDARD NO.: GGNS-JS-09 APPENDIX:C REVISION: 0 PAGE30F6 2.0 IR EFFECTS FOR A CURRENT SOURCE LOOP (General Example)

The model shown below represents a typical transmitter loop with potential leakage current paths associated with the cables, cable splices and a penetration. This model and the analysis techniques that follow are intended as a guide and can be modified to detennine the insulation resistance effect for loops with different physical configurations.

SPLICE CABlE $PUCE PENETRATION

+

R13 R23 R33 R43 R11 Figure C-1 Where:

Is = Transmitter output, current source vs = Loop power supply, voltage source R X1 = Leakage current resistance path from conductor 1 to ground RX2 = Leakage current resistance path from conductor 2 to ground RX3 Leakage current resistance path from conductor 1 to conductor 2

~ = Load resistance Note: Rxl , RX2, and RX) should be referenced from LOeA simulation qualification test reports as described in the previous section.

STANDARD NO.: GGNS-JS-09 APPENDIX;C REVISION: 0 PAGE40F6 In general, the leakage resistance paths shown in Figure C-I can be grouped into three different types: paths between conductor 1 and conductor 2, paths from conductor 1 to groWl~ and paths from conductor 2 to ground. Ifthese distinctions are made, the original model may be reduced by combining like resistance paths using the equations shown below to fonn the equivalent model shown in Figure C-2.

Combining all paths from conductor 1 to ground:

Combining all paths from conductor 2 to ground:

Combining all conductor - to - conductor resistances:

tIl 1 1

-=-+-+-+-

Ree R13 R23 R33 R43

+

RCC RC1 Figure C-2

STANDARD NO.: GGNS-JS-09 APPENDIX:C REVISiON: 0 PAGE 5 OF6 Again, the circuit ofFigure C..2 can be reduced to further simplify the model by using the equation below to yield the equivalent circuit of Figure C-3.

Combining the potential leakage current path resistances:

1 1

---=-+---

R'.F.AKAGE R cc ReI + R C2

'lEAKAGE

+

+

Figure C-3 Ideally, ifno leakage resistance paths existed, the source current (Is) and the current delivered to the load (Ito.J would be equivalent. However, due to the postulated degradation ofthe insulation resistance, the leakage resistance is no longer so great that leakage current is negligible. As the leakage resistance decreases the leakage current (or IR effect) becomes greater. To relate this effect to loop Wlcertainty, the leakage current must be determined using the following equations from basic circuit analysis.

From Figure C-3, the source current is the difference between the current delivered to the load and the leakage current:

Is = I WAD -ILEAKAGE OR II.f:AKAGE + Is =I WAD

STANDARD NO.: GGNS-JS-09 APPENDIX: C REVfSION:O PAGE60F6 Also from Figure C-3, the source voltage is given by:

Vs = I J.EAKAGE (R LEAKAGE) + I LOAD (R LOAD)

Or equivalently:

Substituting for ILoad and solving for ILcaIcaae :

- .Vs - (1 U.AKAGE + Is )RI.OAD I I.EAKGE -

RLEAKA(;E Therefore, the leakage current is given by:

_ Vs -ls(RWAD )

I U:AKAGE -

RLEAKAGF. + RLOAD And the leakage resistance in percent ofspan, or IR Effect is:

I (C?Ic SPAN) - II.F..AKAGE (100%)

LEAKAGE 0 - I -1.

Smax Smm The equations above lead to the following general conclusions regarding insulation resistance effects for current loops:

• The IR effect for a transmitter (current) loop is a positive bias with respect to the loop current.

• The IR effect increases with increased source (power supply) voltage.

• The IR effect increases with decreased source (transmitter) current.

• The IR effect increases with decreased load resistance.

STANDARD NO.: GGNS-JS-09 APPENDJX: 0 REVISION: 0 PAGE 1 OF3 APPENDIXD ACRONYMS AND ABBREVIATIONS

STANDARD NO.: GGNS-JS-09 APPENDIX:D REVISION: 0 PAGE 2 OF3 ACRONYMS AND ABBREVIATIONS AL Analytical Limit AL Loop Device Uncertainty AV Allowable Value Ax Individual Device Uncertainty CL Loop Calibration Uncertainty DBE Design Basis Event DL Loop Drift DR Device Drift F Arbitrarily Distributed Loop Uncertainties HE Hwnidity Effects HELB High Energy Line Break IR Insulation Resistance Effects ISA Instrument Society ofAmerica L Bias in the Negative Direction LER Licensee Event Report LSL Licensing Safety Limit LV Loop Uncertainty M Bias in the Positive Direction MTE Measurement and Test Equipment Effects NTSP Nominal Trip Setpoint n Number of Standard Deviations OVP Overpressure Effects PAM Post Accident Monitoring

STANDARD NO.: GGNS-JS-09 APPENDIX: D REVISION: 0 PAGE 3 OF 3 PE Primary Element Uncertainty PL Process Limit PM Process Measurement Uncertainty PS Power Supply Effects RA Reference Accuracy RD Radiation Drift RE Radiation Effects Rl Readability of Indicator RLU Random Loop Uncertainty SE Seismic Effects SPE Static Pressure Effects SRSS Square Root Swn of the Squares SSE Safe Shutdown Earthquake T Magnitude of the Limiting Transient Variation Tc Modeling Bias or Uncertainty TE Temperature Effects TD Temperature Drift Effects TLV Total Loop Uncertainty URL Upper Range Limit

~ Max. or Min. Steady State Loop Operating Value XT Magnitude ofthe Limiting Operating Transient

[_li_.. En_li_t!f8Y 5_0_.S_9_SC_R_'i!_!_N_IN_G 1Page I2Ll 3 Facility: Grand Gulf Nuclear Station I. SIGNATURES I ~~~~~(~J_f_~_~~~~~~~A_~_J_.B_ro_~~~~I~

Signature Name (print) Date Signature Name (print) Date II. OVERVIEW Document Evaluated: (Include document number, revision, and title)

GGNS-JS-09, Rev. 1 - Methodology for the Generation of Instrument Loop Uncertainty & Setpoint Calculations Brief Description of the Proposed Change:

General revision and incorporate SCN 98-0001 III. 50.59 SCREENING TECHNICAL SPECIFICATION SCREENING Does the proposed Change represent a change to:

Operating License 0 Yes If yes, process a change per 10CFR50.90 and

~ No obtain NRC approval prior to implementing the Change. .

TechnicaJ Specifications 0 Yes If yes, process a change per 10CFR50.90 and

~ No obtain NRC approval prior to implementing the Change.

NRC Orders 0 Yes If yes, process a change per 10CFR50.90 and (ANO only) 0 No obtain NRC approval prior to implementing the

_____________ ~ N/A Change.

SAR SCREENING Does the proposed Change rep.....nt a chang. to the facility or procedure which altera Information, operdon, function or ability to perform the function of a system, structure or compon.nt described In the BAR (site-specific documents)?

TS Bases section DYes If yes, perform a 50.59 Evaluation.

~ No UFSAR (including pending changes) o Yes If yes, perform a 50.59 Evaluation.

~ No TRM o Yes If yes, perform a 50.59 Evaluation.

~ No ATTACHMENT: :L-TO: 6C:,NS - 3~t" J PAGE~OJ;: 3

I_A_-:'::"_En_tergy 5_0_.5_9_S_C_R_E_E_N_IN_G ~1 Page I~ 3 I Core Operating Limits Report 0 Yes If yes, perform a 50.59 Evaluation.

~ No Fire Hazards Analysis 0 Yes If yes, perform a 60.59 Evaluation.

(Included in RBS' USAR) ~ No 0 N/A NRCSERs 0 Yes If yes, perform a 50.59 Evaluation.

I8J No (See section 5.1.19.)

Do.. the propoaed Change Involve a teat 0 Yes If yes, perform a 50.59 Evaluation.

or experiment not described In the SAR? ~ No Does the proposed Change result In any DYes If yes, perform a 72.48 Review.

potential Impact to equipment or facilitlee ~ No utilized for Ventllateet Storage C..k activities?

D N/A ADDITIONAL SCREENING Does the proposed Change represent a change to:

Quality Assurance Program Manual 0 Yes If yes, notify the quality department and ensure

~ No a 50.54 Evaluation is performed.

Emergency Plan 0 Yes If yes, notify the emergency planning 181 No department and ensure a 50.54 Evaluation is performed.

BASIS: [A brief written response providing the basis for answering the questions must be provided. Adequate basis must be prOVided within the Screening such that a third-party reviewer can reach the same conclusions.

Simply stating that the change does not affect TS or the SAR is not an acceptable basis. Also discuss the methodology for performing the LBO search. State the location of relevant licensing document information and explain the scope of the review such as electronic search criteria used (e.g' t key words) or the general extent of manual searches per Section 5.1.18.6.]

Standard GGN8-JS-09 presents the methodology for the generation of instrument loop uncertainty and setpoint calculations. This standard is intended to promote uniformity in instrument calculations performed at GGNS, and is based on accepted industry standards.

JS-09 is not specifically addressed in the Technical Specifications or the SAR. The changes made in Revision 1 of JS-09 will not invalidate the general descriptions of setpoint I allowable value development contained in the Tech. Spec. Bases.

Electronic search keywords: setpoint methodology I JS-09 Documents searched: UFSAR, Technical Specifications, TRM AnACHMENT: :1-TO: C:;6N~ - 3~v /

PAGE~OE.-;"1~_

_~._EJ_ntergy

.... ......... 5_0_.5_9_S_C_R_E_E_N_IN_G 1Page [ILl 3 IV. ENVIRONMENTAL EVALUATION APPLICABILITY REVIEW If any of the following questions Js answered "YES", then an Environmental Evaluation must be performed.

Will the Change being evaluated:

YES NO 0 ~ Disturb land that is beyond that initially disturbed during construction (I.e., new construction of bUildings, creation or removal of ponds, or other terrestrial impact)?

0 ~ Increase thermal discharges to the river, lake or atmosphere?

0 [8J Increase concentration or quantity of chemicals discharged to the atmosphere, ground water, or surface water?

0 ~ Increase quantity of chemicals to cooling lake or atmosphere through discharge canal or tower?

0 I8J Modify the design or operation of cooling tower that will change now characteristics?

0 Jg1 Install any new transmission Unes leading offsite?

0 ~ Change the design or operation of the intake or discharge structures?

0 181 Discharges any chemicals new or different from that preViously discharged?

0 181 Potentially cause a spill or unevaluated discharge that may effect neighboring soils, surface water or ground water?

0 181 Involve burying or placement of any solid wastes in the site area that may effect runoff, surface water or ground water?

0 ~ Involve incineration or disposal of any potentially hazardous materials on the site?

0 ~ Result in a change to non-radiological effluents or licensed reactor power levet?

0 ~ Potentially change the type or increase the amount of non-radiological air emissions from the site?

ATTACHMENT; 2-TO: 6C;zNS - 3~"OCf 'T<tvl PAGE~OE_..l__

Date: 11'1<<1 To: Mr. J. E. Venable, GONS General Manager, Plant Operations From: A. D. Barfield, Manager, Design Engineering

Subject:

Engineering Issuance of Standard GGNS-JS-09, Revision 1, for Use Title Methodology for the Generation of Instrument Loop Uncertainty &

Setpoint Calculations Engineering is issuing the subject Standard for use at GGNS.

X The subject specification/standard was not issued for review. Therefore, if this issuance impacts any procedure, requires re-training, or effects materials, contact Engineering.

The subject specification/standard was previously issued for review. All comments have been incorporated. Plant review indicated no material impacts, retraining, or procedure revisions are required.

The subject specification/standard was previously issued for review. All comments have been incorporated. Plant review indicated material impacts, retraining, or procedure revisions are required. See the attached completed Advance Change Notification Department Response.

It should be noted that a master reproducible copy of this document is being transmitted to Plant Staff Document Control so that members of your staff will be able to obtain controlled copies.

FJB: ~

Attaebm:-; . -! -

pc: E. D. Harris, w/a (M&E1Engineering), w/a J. C. Roberts (BADMlQP), w/o C. D. Stafford (G-ADMI-0PS), w/a D. P. Wiles (U2WHSElMATL), w/a Configuration. Management (ESC), w/a File (applicable), w/a File (NPE), w/o FORM 0I5- 9/1/1999

Date: ,V6/~P"o To: Ms. K. M. Bilbro, Document Control Supervisor From: M. L. Humphries, Group SUPervisor, Electrical! I&C Subjeet: File Documentation DOCUMENTN~ANDNUMBER DCP: _ CALC: _

MCP: _ eN: _

OTHER: GGNs-JS-09, Rev. 1 Documents are attached and fi rwarded for inclusion in the appropriate subject file.

Total number of pages iDeluding this sheet __ 3o..--~

FORM03S-9I21J 999

ENGINEERING PROGRAMS APPLICABILITY REVIEW/ACCOUNTABILITY RECORD Document Evaluated GGNS*JS-09 Rev. _1_ Supplement N/A Brief Description of Change General revision and incorporate SeN 98/0001 N/A NO YES NIR ALARA (if YES, refer to NPEAP 311) Does document install or modify a component: I) where radiation exposure to plant personnel (> 2.5 mremlhr) can occur either during nonnal or outage conditions, or during manipulation ofan sse following an accident; 2) involve work inside the

• D D D fluid boundary of a radioactive system; 3) require a modification of shielding; or 4) is there a potential for Cobalt reduction in systems communicating with the Reactor Vessel? Note: Records of plant radiological conditions during various operational modes are maintained by the GONS Health Physics department SEISMIC QUALIFICATION (if YES, refer to NPEAP 314) Does document delete or modify seismically qUalified equipment; install new safety related or post accident monitoring equipment, or affect equipment which interacts with seismically qualified equipment in a manner which could D

• D D affect the performance capabilities or seismic/dynamic characteristics?

FIRE PROTECTION (if YES, refer to NPEAP 3) 7) Does document involve or affect combustibl~ fire protection equipment, obstructions to tire suppression/detection features.

penetrations! space separators, or structural steel fireproofing, raceway fll'C barrier enclosures

• 0 D D (Thcnno-LqlKaowool). cabJe tray covers or Pre-Fire Plans; add or remove safety related equipment?

SAFE SHUTDOWN (if YES, refer to NPEAP 317) Does document involve equipment listed in FPP-J, described on safe shutdown PetlD drawings, or involve any of the following systems; B2l, EJ2, P41, P7S, T46, TSl, X77, Y47, C61, M7J, Z77, or systems which support these systems; address a change to equipment in an area containing redundant safe shutdown components; involve

• DOD non-safe shutdown circuits that share power supplies, signal sources or enclosures with safe shutdown circuits; or affect the function of 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> emergency lighting?

HUMAN FACTORS (if YES, refer to NPEAP 333) Does document include a change to control room labeling or annunciator wording which differs from, or is not listed in Appendix A of ES-17; or modifies display equipment on control room panels or control room operator controls?

o* 0 D HYDROGEN CONTROL (if YES, refer to NPEAP 336) Does document address a change to equipment or structures in the containment or drywell? o

• D D ASME SECTION XI (if YES, refer to NPEAP 337) Does document add or delete any safety related pressure boundary welds, components, or component supports~ affect the performance or testing of a safety related pump or safety related valve; or the function or function classification of D

• 0 D any pump or valve as stated in GGNS-M-189.3?

ENVIRONMENTAL QUALIFICATION (if YES, refer to NPEAP 803) Does document add EQ equipmen~ remove, replace, change the function of, change the power supply of or alter any EQ equipment; result in a change or potential change to local environmental conditions (e.g.,

o* D D heat load, cooling source or radiation source) during normal, abnormal or post accident operations including changes to HELB barriers (c.g. doors)~ add, change or alter safety related equipment located inside a line break area/containment which share common power supplies or circuit breakers with EQ equipment; or alter a system required to detect/mitigate a LOCA or HELB?

EROSION/CORROSION - MIC (if YES, refer to NPEAP 903) Does the document affect any aspect of a water/steam system (e.g., flow path geometry, material. flow rate, duration, chemistry, new weld location, temperature, pressure, or steam quality); or affect the piping component wall thickness (e.g., welding overlay, different pipe schedule, eroded areas, etc.) for

• D D D elbow, tee, reducer, piping, pump, tank. or valve within the piping system (not to include pipe supports); or add external weight to the piping system (such as lead shielding or larger actuator); or make any changes to the drawings listed in Attachment 1 to NPEAP 903?

Justification: Revision 1 of J8-09 is a general revision and incorporates SeN 98/0001.

These changes consist of minor methodology revisions, editorial changes and updates to references.

The revision does not impact the original design inputs.

Responsible Engineer: ~~~~1/;: ? ------=~...- - -Date*or JfrobcuJ f

Group Supervisor: ~/_:lI;,..&_......_~~~-CI'I~-=-------------Date: ~/~~

Form 330.2, Rev. 4

Page 1 of 1 DESIGN VERIFICATION RECORD Document Number: JS-09 Revision: 1 METHOD Verification methods to be used:

x Design Review

---

Qualification Testing

- - - - - Alternate Calculations DOCUMENT(S) REVIEWED: (Attach Additional Sheet(s), if needed)

Document Number Revision Document Title NEDC~31336P-A 1996 GE setpoint methodology ISA RP67.04, Part II 1994 ISA setpoint methodology EDP-032 1 Setpointluncertainty desktop procedure USNRC RG 1.105 1 NRC instnunent setpoint reg guide J8-09 o

SUMMARY

OF REVIEW: (Attach Additional Sheet(s)t if needed)

A review was done to verify the accuracy of the infonnation presented in J8-09 rev 1. A review was done to ensure that aU procedural requirements were met. J8-09 rev 1 is acceptable for issuance. The methodology for generating instrument \U1certainty and setpoint calculations is adequately explained.

Design Verification Completed By: c-:~~_. Date: \./ b /0 0

• SUperviSOr.

Englneenng . /1/./ ~"?t I1fl /.

-..-..I-.&.&...-....;~~;~~"'i'-~....,;..;;~---

ES-P-002, Form No.1, Rev. 0 For GGNS