L-2025-202, Supplement to License Amendment Request L-2024-185, Licensing Basis Changes in Support of St. Lucie Unit 2 Transition to 24-Month Fuel Cycles

Supplement to License Amendment Request L-2024-185, Licensing Basis Changes in Support of St. Lucie Unit 2 Transition to 24-Month Fuel Cycles

ML25349A027
Person / Time
Site:	Saint Lucie  (NPF-016)
Issue date:	12/15/2025
From:	Mack K Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2025-202
Download: ML25349A027 (0)

Text

{{#Wiki_filter:U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 RE: St. Lucie Nuclear Plant, Unit 2 Docket No. 50-389 Renewed Facility Operating License NPF-16 December 15, 2025 L-2025-202 10 CFR 50.90 10 CFR Appendix H Supplement to License Amendment Request L-2024-185, Licensing Basis Changes in Support of St. Lucie Unit 2 Transition to 24-Month Fuel Cycles

Reference:

1.

Florida Power & Light Company letter L-2024-185, License Amendment Request L-2024-185, Licensing Basis Changes in Support of St. Lucie Unit 2 Transition to 24-Month Fuel Cycles, dated November 26, 2024 (ADAMS Accession No. ML24331A255, ML24331A249)

2.

Response to Requests for Additional Information and Confirmatory Information Regarding License Amendment Request L-2024-185, Licensing Basis Changes in Support of St. Lucie Unit 2 Transition to 24-Month Fuel Cycles, July 30, 2025 (ADAMS Accession No. ML25211A136) In Reference 1, Florida Power & Light Company (FPL) requested an amendment to Renewed Facility Operating License (RFOL) No. NPF-16 for St. Lucie Nuclear Plant, Unit 2. The proposed change would revise Technical Specification (TS) 5.5.16, Surveillance Frequency Control Program (SFCP), to increase certain Surveillance Requirement (SR) Frequencies in support of the 24-month fuel cycle transition. In addition, changes were proposed to certain Reactor Protective System (RPS), Engineered Safety Features Actuation System (ESFAS), and Diesel Generator (DG) - Loss of Voltage Start (LOVS) instrument allowable values and trip setpoints, to the maximum boric acid concentrations for the Refueling Water Tank (RWT) and Safety Injection Tanks (SITs), and to the reactor vessel (RV) surveillance capsule withdrawal schedule in support of the 24-month fuel cycle transition. In Reference 2, FPL provided its response to the NRC staff's requests for additional information (RAls) regarding the subject license amendment request. During a subsequent December 8, 2025 meeting regarding the proposed license amendment, the NRC staff requested a copy of FPL's Nuclear Engineering Department Discipline Standard, IC-3.17, "Instrument Setpoint Methodology", Revision 8. The attachment to this letter provides the requested FPL standard. The information provided in this license amendment request supplement provides additional information that clarifies the application, does not expand the scope of the application as originally noticed, and should not change the NRC staff's originally proposed no significant hazards consideration determination as published in the Federal Register. This letter contains no new regulatory commitments. Should you have any questions regarding this submission, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164. Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

St. Lucie Unit 2 Nuclear Plant Docket No. 50-389 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 15th day of December 2025. Sincerely, 6 h. Kenne Director, Licensing and egulatory Compliance Florida Power & Light Company

Attachment:

L-2025-202 Page 2 of 2 Nuclear Engineering Department Discipline Standard, IC-3.17, "Instrument Setpoint Methodology", Revision 8 cc: USNRC Regional Administrator, Region II USNRC Project Manager, St. Lucie Nuclear Plant, Units 1 and 2 USNRC Senior Resident Inspector, St. Lucie Nuclear Plant, Units 1 and 2 Mr. Clark Eldredge, Florida Department of Health

St. Lucie Unit 2 Nuclear Plant Docket No. 50-389 Nuclear Engineering Department Discipline Standard, IC-3.17 Instrument Setpoint Methodology, Revision 8 (79 pages follow) L-2025-202 Attachment

NUCLEAR ENGINEERING DEPARTMENT DISCIPLINE STANDARD STANDARD NO.: IC-3.17 REV._8_ DISCIPLINE: INSTRUMENTATION & CONTROL INSTRUMENT SETPOINT METHODOLOGY FOR NUCLEAR POWER PLANTS Lionel D Bates Digitally signed by Lionel D Bates Date: 2024.11.07 10:26:07 -07'00' Prepared by: ______________ Date: Br.la n Digitally signed by Brian Davidson Davidson ~~'.~~~024.11.0714:14:03 Reviewed by: ______________ Date: Ra I Ph Digitally slgned by Ralph Heistand ON: cn=Ralph Heistand, o=FPL, ou=Capital Design Supervisor, He

• 1 stand emall=ralph.heistand@fpl.com, c=US Date: 2024. t 1.08 16:13:57 --05'00' Approved by: ______________ Date:

Discipline Mgr./Supervisor Approved by:. _____ N_A ________ Date: (if appl) Chief Elect/l&C Engineer Approved by: _____ N_A _________ Date: (if appl) Manager-CSI

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page ii LIST OF EFFECTIVE PAGES PAGE REVISION PAGE REVISION PAGE REVISION 8 Al 7 ii 8 A2 7 iii 8 A3 7 iv 8 A4 8 1 8 AS 8 2 8 A6 8 3 8 A7 7 4 8 A8 8 5 7 A9 8 6 8 A10 8 7 8 A11 8 8 7 A12 8 9 7 A13 8 10 7 A14 8 11 7 A15 8 12 8 A16 8 13 8 A17 8 14 8 A18 8 15 8 A19 8 16 8 A20 7 17 8 A21 8 18 8 A22 8 19 8 A23 8 20 8 A24 8 21 8 A25 8 22 7 A26 8 23 8 A27 8 24 8 A28 8 25 8 A29 8 26 8 A30 8 27 8 81 7 28 7 82 7 29 8 83 7 30 7 84 8 31 7 BS 7 32 7 ATTCH1-1 8 33 8 ATTCH1-2 8 34 8 ATTCH2-1 8 35 8 ATTCH2-2 8 36 8

Revision 5 6 7 8 Instrument Setpoint Methodology Description IC-3.17 Rev. 8 Page iii Added "As-Found/As-Left Guidelines" for St. Lucie to Appendix A. Updated description of St. Lucie Control Classes in Appendix A. Repaginated document and made various minor changes. Added "Revision History" page. Added Appendix B, "Turkey Point Setpoint Program Plan and Specific Guidelines/Assumptions." Made minor formatting and pagination changes. Revised Appendix A to capture the delineation of responsibility related to revision of safety related Engineering calibration calculations (Reference St. Lucie Condition Report 97-2092, LER 97-011, and ERT 97-35) Revised to conform to Regulatory Guide 1. 105 Revision 3. Revised Appendix A to expand on the use of As-Found and As-Left calibration data as applied to extended surveillance intervals for 24-month fuel cycles. Documented two exceptions to application of RPS/ESFAS WCAP setpoint methodology to St Lucie. Added Attachments 1 and 2 which are Emerson/Rosemount Industry letters and modified text of body to reflect letters effects on Static Line Pressure uncertainties and statistical content of Rosemount performance parameters.

SECTION II 111 IV V VI VII VIII IX X XI XII APPENDICES A B ATTACHMENTS 1 2 Instrument Setpoint Methodology IC-3.17 Rev. 8 Page iv TABLE OF CONTENTS INTRODUCTION DEFINITIONS ABBREVIATIONS GENERAL GUIDELINES/ASSUMPTIONS DESCRIPTION OF METHODOLOGY ELEMENTS OF DEVICE UNCERTAINTY OTHER SOURCES OF UNCERTAINTY SETPOINT DETERMINATION DATA TO PERFORM INSTRUMENT LOOP ERROR CALCULATIONS SOURCES OF DATA INSTRUMENT SETPOINT CALCULATION FORMAT REFERENCES ST. LUCIE SETPOINT PROGRAM PLAN,SPECIFIC GUIDELINES/ASSUMPTIONS, AND AS-FOUND/AS-LEFT GUIDELINES TURKEY-POINT SETPOINT PROGRAM PLAN AND SPECIFIC GUIDELINES/ASSUMPTIONS INDUSTRY LETTER EMERSON/ROSEMOUNT 3150 SERIES HIGH STATIC LINE PRESSURE SPECIFICATIONS-8/12/2024 (2 pages) PAGE 1 3 7 8 10 12 21 23 30 31 33 36 A1 B1 INDUSTRY LETTER ROSEMOUNT NUCLEAR PRESSURE TRANSMITTER 3150 SERIES PERFORMANCE SPECIFICATIONS-11/16/2018 (2 pages)

I. 1.0 2.0 3.0 Instrument Setpoint Methodology INTRODUCTION GENERAL DISCUSSION IC-3.17 Rev. 8 Page 1 of 36 This Setpoint Methodology Standard has been developed specifically for the Turkey Point Units 3 and 4 and St. Lucie Units 1 and 2 Nuclear Facilities. It is the intention of this document to provide a consistent, programmatic methodology to calculate new setpoints or to assess the impact of proposed plant modifications on existing setpoints. The methodology is not intended to supersede any setpoint calculations performed previously by Florida Power & Light (FPL), contractors, or vendors. Regulatory Guide 1.105, Revision 3, "Instrument Setpoints for Safety Related Systems" endorses the use of ISA Standard 67.04 - 1994, "Setpoints for Nuclear Safety-Related Instrumentation". Although FPL nuclear plants are not committed to this RG, this methodology has been written to meet its intent. ISA Recommended Practice 67.04 Part II is also an excellent source of additional information relevant to the topics encompassed by this methodology. Regulatory Guide 1.105 Rev. 3 describes the revision of the ISA Standard by stating: "ISA-S67.04 was revised in 1987 to provide clarification and to reflect industry practice. The standard was revised further in 1994. The effects of uncertainty allowances and discrepancies in setpoints, along with operational experience, were appropriately addressed during this revision of ISA S67.04. This 1994 revision of the standard also reflects the Improved Technical Specification program (a cooperative effort between industry and the NRC staff) and reflects current industry practice." PURPOSE A systematic method of identifying and combining instrument uncertainties is necessary to ensure that vital plant protective features are actuated at the appropriate point during transient and accident conditions. Safety limits have been established through the process of accident analysis which assumed that plant protective features would intervene to arrest and turn a transient. Ensuring that these protective features enter into the actual transient as they were assumed in the accident analysis provides certainty that safety limits will not be exceeded. APPLICABI LIJY This Instrument Setpoint Methodology is confined to those devices providing analog signals (e.g. pressure transmitters) or devices which actuate at a given signal input point (e.g. pressure switches). Devices such as Timing Relays, Area Radiation Detectors, devices without wires (e.g. safety reliefs and pneumatic devices), Protective Relays, etc. are considered outside the scope of this methodology. New instrument setpoints that require a setpoint calculation and that perform a safety related function or are required for Technical Specification compliance associated with FPL Nuclear Plants shall be developed on the graded approach basis of this standard with the

4.0 Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 2 of 36 exception of the Reactor Protection System (RPS) and Engineered Safety Features Actuation System (ESFAS) at St. Lucie Units 1 &2 and Turkey Point Units 3 & 4. Those RPS and ESFAS setpoints were established using the Westinghouse methodology described in WCAP-17504 for PSL (with the exception of the Loss of Load (Turbine Hydraulic Fluid Pressure - Low) [TS Table 3.3.1-1 Function 1 O] and RWT Level-Low [TS Table 3.3.3-1 Function 5.a] which are both governed by IC-3.17 methodology]) and WCAP-12745 for PTN. For consistency, any new or modified Turkey Point RPS or ESFAS setpoints should follow the methodology described in theWCAP. Unless otherwise indicated, the original calculations are the accepted basis for the plants operating license. These documents are not required to be modified to comply with the specific requirements of this document. This standard is not required for non-safety related function setpoints. However, it is encouraged that this standard should be used to the extent possible. Outside organizations tasked with developing setpoints for the afore-mentioned FPL generating stations shall, unless otherwise directed by FPL, as a minimum, address the topics of this standard. GRADED APPROACH CONSIDERATION The importance of the various types of Safety-Related and Technical Specification setpoints differ and as such, it is appropriate to apply different levels of setpoint determination requirements. Regulatory Guide 1.105 Rev. 3 addresses the subject of graded approach by stating: "Section 4 of ISA-S67.04-1994 states that the safety significance of various types of setpoints for safety-related instrumentation may differ, and thus a less rigorous setpoint determination method may be applied for certain functional units and limiting conditions of operation (LCOs). A setpoint methodology can include such a graded approach. However, the grading technique chosen should be consistent with the standard and should consider applicable uncertainties regardless of the setpoint application." "Additionally, the application of the standard, using a "graded" approach, is also appropriate for non-safety system instrumentation for maintaining design limits described in the Technical Specifications. Examples may include instrumentation relied on in emergency operating procedures (EOPS), and for meeting applicable LCOs, and for meeting the variables in Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants To Assess Plant and Environs Conditions During and Following an Accident." For setpoints that provide automatic protection with significant importance to safety such as RPS and ESFAS, a stringent setpoint methodology that considers all the elements that may affect the performance of the instrument loop should be used. Other Safety-Related and Technical Specification setpoints which perform a true safety-related function, (i.e. utilized in a safety analysis, necessary for safety system operation, etc.),

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 3 of 36 should also utilize a stringent methodology that considers all known instrument loop uncertainties and effects. For those setpoints that provide a lesser level of importance, for example, those that are not credited in the safety analysis or do not have limiting values, a less rigorous setpoint determination may be appropriate. It is up to the user to determine, justify and document the level of requirements for the particular setpoint in question. Refer to the appropriate plant specific Appendix A or B for further clarification of the plant specific considerations of the Graded Approach.

11.

DEFINITIONS A. Accuracy (A) A number or quantity that defines a limit that errors will not exceed when a device is used under specified operating conditions. Includes all sources of errors not due to environmental variations such as Hysteresis, Repeatability, Linearity, and dead band. B. AD'95/95 (ADJWID.) C. D. E. The ADRANo 95/95 term denotes a statistically analyzed drift value at 95% confidence and 95% probability. These values are derived from historical calibration data in accordance with statistical methodology described in Reference 3, STD-IC-3.19 Revision 0, "Design Standard for Analysis of Instrument Drift Data." As-Found Tolerance (AFT) The instrument loop as-found tolerance is the criteria applied to the loop as-found data during calibration to ensure that the loop was operating within the TS limits, or for non-TS instruments, operating within the analytical limits. This acceptance criteria usually does not include margin but may as long as it is justified in the calculation. This value includes consideration of ADRANo drift determined by the methods of Reference 3. As-Left Tolerance (ALI) The limits of the values that an instrument or component may be left at during calibration. The ALT values include the M&TE accuracy of the instruments used for calibration, the readability of the M&TE, and the accuracy of the instrument/loop being calibrated. Allowable Value (AV) The limiting value that the nominal setpoint can have when tested periodically beyond which appropriate action must be taken in accordance with Technical Specifications. Regulatory Guide 1.105 Rev. 3 defines AV as: "The allowable value is the limiting value that the trip setpoint can have when tested periodically, beyond which the instrument channel is considered inoperable and corrective action must be taken in accordance with the technical specifications."

F. G. H. I. J. Instrument Setpoint Methodology Analytical Limit (AL) IC-3.17 Rev. 8 Page 4 of 36 The limit of a measured or calculated variable established by the safety analysis to ensure that a safety limit and/or design conditions of equipment/systems is not exceeded. Bias Terms (B) Bias terms are the fixed or systematic uncertainty components within a measurement and are not generallyeligiblefor Square Root sum of the Squares (SRSS) combinations. Examples of bias are head effects, range offsets, reference leg heatup, etc. There are generally three types of bias error terms encountered in instrumentation: The first has a known sign, (unidirectional) and a well-defined and predictable limit of magnitude. An example of such a bias is the static pressure effect of differential pressure transmitters which exhibit a predictable span shift because of changes in static pressure. This type of bias is generally calibrated out during calibration and thus eliminated. The second has an unknown sign. Their unpredictable sign should be conservatively treated by algebraically adding the bias in the conservative direction. The third are those uncertainties that have unknown sign and unknown magnitude and may not be normally distributed. This type of bias is treated as the maximum predicted uncertainty against both the positive and negative components of the module uncertainty. Dead Band (DB) (Reset or Differential) Dead band is a control phenomenon which can affect an instrument loop's performance. Dead band is the term given to the band of non-response in the output for a change in input when an instrument's input reverses direction. Dead band is found in both analog and digital (setpoint) devices. In analog devices, the dead band typically is part of the basic accuracy of the device and affects the device's ability to respond to a change in input signal. For digital or setpoint devices, the dead band affects the point at which a device resets after returning to the de-actuation level from the actuation level and may be desirable and even required. In general, dead band does not have to be considered in loop error analysis. However, the dead band should be evaluated during the final setpoint determination to assure that cycling, chatter and system instability are avoided. Dependent Terms Dependent uncertainties are those for which the user knows or suspects a common root cause exists which influences two or more of the uncertainties with a known relationship. Drift (D) Drift is an undesired change in output over a period of time where change is unrelated to the input, environment, or load. This value is usually specified by the equipment/instrument vendor.

I<. L. M. N.

0.

P. Q. R.

s.

Instrument Setpoint Methodology Hysteresis (H) IC-3.17 Rev. 8 Page 5 of 36 Maximum deviation of two output signals generated by identical values of measured variable, when first approaching the measured variable from up range and the second from downrange. Independent Terms Uncertainty components are independent of each other if their magnitudes or algebraic signs are not significantly correlated (no common root cause). Instrument Range The region between the limits within which a quantity is measured, received, or transmitted, expressed by stating the lower and upper range values. Linearity (L) The closeness to which a linear device's output curve approximates an ideal straight-line output. Margin An additional allowance added to the instrument uncertainty. Margin moves the setpoint farther away from the analytical limit. Nominal setpoint (SP) The most limiting value (no additional margin included) at which a bistable type of device is to change state in order to ensure that the analytical limit is not surpassed. Random Terms Those uncertainty terms whose values at a particular future instant cannot be predicted exactly but can only be estimated by a probability distribution function. The algebraic sign of a random uncertainty is equally likely to be positive or negative with respect to a median value. In the context of this document, "random" is an abbreviation for "random, approximately normally distributed". Repeatability (REP) The closeness of agreement among consecutive measurements of the output for the same value of the input under the same operating conditions, approaching from the same direction, for full range traverses. Does not include hysteresis. Safety Limit (SL) A limit on an important process variable that is necessary to protect the integrity of physical barriers that guard against uncontrolled release of radioactivity.

T. Instrument Setpoint Methodology Setpoint IC-3.17 Rev. 8 Page 6 of 36 A predetermined value at which a bistable device changes state to indicate that the quantity under surveillance has reached the selected value.

u.

Sp.an V.

w.

The term "span" is the algebraic difference between minimum and maximum range values. Examples: Calibrated Span (CS) is the upper calibration value less the lower calibration value. Maximum Span (MS) is the instrument's maximum or upper range limit less its minimum or lower range limit. Standard Deviation The positive square root of the variance of a probability distribution function. For normal distributions, 68.3%, 1 o (sigma), of the area under the probability distribution function lies within the range of {(x-o) to (x+o)}. 95.5%, 20, of the area lies within the range of {(x-2o) to (x+2o)}; and 99.7%, 3a, of the area lies within the range{(x-3o) to (x+3o)}. (xis the mean value of the probability distribution function). Uncertainty The amount to which an instrument channel's output is in doubt (or the allowance made therefore) due to possible errors, either random or systematic, which have not been corrected for. The uncertainty is identified within a probability and confidence level. Regulatory Guide 1.105 Rev. 3 defines the regulatory intent for Technical Specification related uncertainty criterion as follows: "Section 4 of ISA-S67.04-1994 specifies the methods, but not the criterion, for combining uncertainties in determining a trip setpoint and its allowable values. The 95/95 tolerance limit is an acceptable criterion for uncertainties. That is, there is a 95% probability that the constructed limits contain 95% of the population of interest for the surveillance interval selected."

Ill. ABBREVIATIONS Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 7 of 36 To aid the reader's understanding, a list of abbreviations used in the methodology is presented below in alphabetical order. A= ADRAND = ADs1As = AFT= ALT= AL= AV= B= CP= CS= CSE= D= DB= DU= H= HU= IR= L= M= MS= N= NLU = OL= P= PC= PL= PU= PS= REP= RE= Ra= Rn= RES= S= SL= SP= SPE= ST= TE= Ta= Tc= Tn = TDF= TLU= URL= V*E= CJ= Reference Accuracy Analyzed Drift Random Analyzed Drift Bias As-Found Tolerance As-Left Tolerance Analytical Limit Allowable Value Bias Term Calibration Period Calibration Span Chemical Spray Effect Drift Deadband Device Uncertainty Hysteresis Humidity Effects Insulation Resistance Linearity Maintenance & Test Equipment (M&TE) Maximum Span Channel Noise Normal Loop Uncertainty (periodically tested portion) Operational Limit Pressure Process Conditions (Process allowance/considerations) Process Limits Process Uncertainty (Primary element) Power Supply Effect Repeatability Radiation Effect Radiation Effect, accident Radiation Effect, normal Readability/Resolution Seismic Effect Safety Limit Nominal Set Point Static Pressure Effect Setting Tolerance see also ALT Temperature Effect Temperature Effect, accident Calibration Temperature Temperature Effect, normal Turn Down Factor Total Loop Uncertainty Upper Range Limit Vendors Stated Effect Standard Deviation

IV. Instrument Setpoint Methodology GENERAL GUIDELINES/ASSUMPTIONS IC-3.17 Rev. 8 Page 8 of 36 The general guidelines and assumptions listed below apply to both St. Lucie and Turkey Point Nuclear Plants. For plant specific guidelines/ assumptions, refer to Appendix A for St. Lucie and Appendix B for Turkey Point. A. If procedures dictate a loop calibration, then those loop instruments calibrated together are considered dependent when determining M&TE, as-found tolerance and setting tolerance allowance. B. IR is a unidirectional bias which only applies to certain accident scenarios. C. Where bias terms have opposite effects on instrument accuracy, (positive vs. negative), and are of unknown magnitude, each must be treated separately and not assumed to offset each other unless specific relationships exist between them. D. Where bias terms have opposite effects on instrument accuracy, (positive vs. negative), are both present at the same time, both have 100% probability of being present, and are both of known magnitude, the two uncertainties may be used to offset each other. If both magnitude and direction of a bias is known, (e.g. transmitter static pressure zero or span effects), this effect can be calibrated out of an instrument and thus eliminated from the uncertainty calculation. E. Any random independent term whose value is less than 1 /1 0 of any of the associated device uncertainties can be statistically neglected. F. Setpoints and all elements of device uncertainty may be calculated in terms of percent calibrated span(% CS) and/or device output (mAdc, Vdc, etc.). Setpoints and Allowable Values may be expressed in process engineering units such as PSIG. G. Device uncertainties are usually derived as a percent of calibrated span (CS) for use in loop uncertainty calculations. Sometimes, however, vendors specify device uncertainties in terms of% maximum span (MS) or% upper range limit (URL). To convert this specification into the correct units, the vendor specification should be multiplied by a ratio of MS to CS. This ratio is known as the Turn Down Factor (TDF) where TDF = (MS/CS) H. A multiplier of 1.25 is used for Technical Specification surveillance frequencies whenever instrument calibration period (CP) is considered by the methodology. The multiplier is included to account for a 25% allowance associated with the calibration period specified by the Technical Specification. I. The methodology describes the sources of uncertainty and loop uncertainty in terms of loop span which corresponds to the process span of the instrument. J. It is important for the user to integrate the setpoint calculation's assumptions and results with the related calibration span calculation and actual applicable plant practices. It is generally good practice to perform the setpoint calculation and the

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 9 of 36 calibration span calculation together. Actual plant practices should be considered and documented when performing the setpoint calculation to assure that they agree with the design inputs and assumptions. Examples of plant practices that should be carefully considered are:

1) static pressure span and zero effects

2)

M&TE instruments

3)

M&TE practices

4) calculated setting tolerance - it must bound the method of calibration

5) head effects K.

Where device uncertainties are derived from values that are based on a standard reference condition, (e.g. temperature vs. fluid densities), care should be taken to assure that all such values have been corrected to the same standard reference condition, or an appropriate justification included.

Instrument Setpoint Methodology V. DESCRIPTION OF METHODOLOGY IC-3.17 Rev. 8 Page 10 of 36 The discussion presented here describes the methodology selected for combining uncertainties which, while conservative in nature, is not unnecessarily restrictive with respect to plant operations. Overly conservative setpoints such as those determined by "Straight Sum" method only may provide unnecessary challenges to the plants safety systems. "Straight Sum" method assumes that all uncertainties occur at the same time, at their maximum values, and all in the same direction(+/-). Industry standard, and the NRG, have accepted a minimum level of random error probability of 95% for instrument error analysis. This 95% probability means that the error exhibited by a component or loop must be less than or equal to its established error at least 95% of the time. The 95% probability represents the deviation value from the mean which encompasses 95% of all measurement variations. Statistically, the 95% value can be shown to be +/-1.96 times standard deviation. For simplicity, a value equal to two times standard deviation (i.e. 2a) is normally used. The Square Root Sum Squares (SRSS) methodology for combining uncertainty terms that are random and independent is an established and accepted analytical technique. The methodology produces a resultant error value which has the same level of probability as the individual terms being combined. The methodology presented here is a combination of the "Straight Sum" and SRSS methodologies. The random elements of uncertainty are combined under the SRSS methodology, and any non-random or bias uncertainties are added algebraically (straight-sum) to the SRSS result. The final form of the uncertainty expression is determined by characterizing each element of uncertainty as: Random, Independent Random, Dependent Non-Random or Bias All random, independent elements can be combined by SRSS as follows: (Equation V-1) where: w, x, & y are random independent elements of uncertainty z is the total uncertainty Random, dependent terms are treated slightly differently. These elements are first combined algebraically according to their dependency to form new independent terms. The independent terms are then combined with other independent terms by SRSS. (Equation V-2) z = (w2 + (x + y)2) 1/2 where: x & y are random, dependent terms w & (x + y) are random, independent terms

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 11 of 36 Non-random or bias elements are not allowed in the SRSS methodology. To include these terms, they must be combined algebraically (straight sum) with the results of the SRSS computation. (Equation V-3) where: z = (w2 + (x + y)2) v, +/- lbl w, x, & y, as defined previously bis a bias term with unknown sign or an uncertainty that is not normally distributed The total positive uncertainty is: +z = +(w2 + (x + y)2) v, + lbl The total negative uncertainty is: -z = -(w2 + (x + y) 2) 1/2 - I bl As stated in Section II and above, random terms are assumed to have approximately normal probability distribution functions for the purposes of this document. Common industry practice is to assume that published vendor specifications are 2cr values unless specific information is available to indicate otherwise. It is up to the individual performing the calculation to ensure that conditions assumed (i.e., values used for device uncertainty and the manner in which the elements of device and loop uncertainty are combined) are consistent with the instrumentation as installed. Departures from the recommended combination of terms can have a significant impact on the calculated value of instrument loop error. Defendable deviations from the methodology should only be made following careful consideration of the effects. To summarize, the general form of the basic expression for this methodology is: (Equation V-4) z = +/- [ (w2 + (x + y)2) 1/2] +/- lbl + v-t where: w, x, & y are random elements x & y are dependent terms w & (x + y) are independent terms bis a bias term with unknown sign or non-normal distribution v & tare, respectively, the cumulative positive and negative bias error terms z is the total resultant uncertainty. The resultant uncertainty combines the random uncertainty with the positive and negative components of the correlated terms separately to give a final total positive and negative uncertainty. The total positive uncertainty is: +z = + (w2 + (x + y)2) v, + lbl + v

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 12 of 36 The total negative uncertainty is: -z = - (w2 + (x + y)2) 1/2 - lbl -t VI. ELEMENTS OF DEVICE UNCERTAINTY The following sources of instrument uncertainty are considered: A. B. Reference Accuracy (A) The maximum deviation of a device's output in respect to its input when the device is used under reference conditions. Reference accuracy cannot be adjusted or otherwise affected by the act of instrument calibration. Rather, it is a performance specification which the instrument is tested against during the calibration to determine the condition of the instrument. For the purpose of this methodology, reference accuracy (A) will assume to include the effects of hysteresis, linearity, repeatability and deadband, unless stated otherwise by vendor literature. Where these effects are not included, the individual omitted components must be included as shown in the following equation. (Equation Vl-1) where: Av = vendor's stated accuracy H = hysteresis (%CS) L = linearity (%CS) REP = repeatability {%CS) DB = deadband (%CS) Reference accuracy is generally considered to be a random, independent uncertainty unless otherwise indicated by the manufacturer. For all Rosemount series 3150 transmitters the published reference accuracy specification statistical content is considered to be +/-3cr (See Rosemount Industry Letter - Attachment 2). Therefore, the published reference accuracy specification may be multiplied by 2/3 to match other 2cr uncertainties. Drift (D) A change in a device's input/output relationship due to time. The drift uncertainty limits are dependent only on the time which has passed since the most recent calibration. Drift is usually specified by the instrument manufacturer in terms of per unit time. The period of drift applied to an instrument for the purpose of this methodology is dependent on the calibration period of the instrument. The calibration period is generally assumed to be either refueling

C. D. Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 13 of 36 cycles or some periodic check period (i.e. monthly calibrations). It is possible that the time between these periods may extend longer than planned. A standard multiplier of 1.25 should be used to account for a longer period of drift. This standard multiplier is based on plant technical specifications that allow for the calibration interval to be extended by 25% beyond the Technical Specification required interval. Any extension other than the standard 1.25 multiplier should be listed as an assumption to the setpoint uncertainty calculation and justification provided. (Equation Vl-2) D = (CP) (Dv) (1. 25) where: Dv = vendor's drift specification per unit of time (%CS/month) CP = instrument calibration period (months} Generally, drift is considered to be a random, independent uncertainty unless otherwise indicated by the manufacturer. Analyzed Drift (AD) Instrument/loop drift may be determined by analysis of calibration data as described in the Engineering Design Standard STD-IC-3.19 Rev 0, "Design Standard for Analysis of Instrument Drift Data" (Reference 3). The focus of this standard is to provide methods for statistical analysis of instrument calibration data to determine drift behavior over time with high confidence and probability. This statistical analysis of calibration data has been performed for most safety-related instruments and protective relays used at St. Lucie Units 1 & 2. See Reports of these drift analysis results in Reference 7. M&TE (M) M&TE is the uncertainty introduced into a device due to the uncertainty of the test instruments. It is assumed in this methodology that the accuracy of the "Standards" used to calibrate the M&TE instruments is such that there is an insignificant effect on the overall uncertainty and that sufficient conservatism exists in the methodology to ignore this effect. The M&TE uncertainty is generally comprised of the reference accuracy of the test instruments and the uncertainty introduced by the inherent inability of the technician to read the instruments. Refer to Section VI for discussion on readability uncertainty. Commonly, multiple test instruments (input/output test equipment) are used to calibrate a single device or loop of devices. Note that an indicator being calibrated may utilize the indication as output verification. Readability of the indicator, in that case, must be included. Combination of the test instrument inaccuracies will be accomplished as follows: (Equation Vl-3) M = (A,2 + RES,2+ A/+ RES/... A/ + RES/) v, An = An (Tl/LI)

E. where: Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 14 of 36 An Tl = accuracy oftest instrument n (%CS of Test Instrument) = calibrated span of test instrument LI = calibrated span of loop instrument RESn = Reading Uncertainty (if applicable) When a string of instruments (a loop) is calibrated together, only one M&TE term will exist for the loop. However, if individual devices are calibrated separately, then M&TE terms will exist for each device. Setting Tolerance (SI) Setting tolerance is defined as the inaccuracy introduced into the calibration process due to the procedural allowances given to the technician during instrument calibration. Setting tolerances are limits against which a calibration is performed in order to test a device for adequate operation. If test procedures are performed such that all the elements of reference accuracy are tested adequately, then inclusion of the setting tolerance term into the overall uncertainty equation would be unnecessary, (commonly defined as calibration performed three times in each direction). Calibrations are not usually performed in the 3-up and 3 down manner. If the calibration is not performed in this manner, then setting tolerance should be included in the overall uncertainty equation. Setting Tolerance should be taken as the device reference accuracy. Specific calibration procedures should be consulted for the appropriate ST value for the device or loop being calibrated. If a string of devices that make up the loop is calibrated as one, then only one setting tolerance exists for the loop. This term should be applied to the last device in the string. F. As-Left Tolerance (ALI) G. ALT is related to ST above but contains more uncertainty terms than the reference accuracy of the device/loop being calibrated. The ALT includes the accuracy of the device/loop being calibrated, the accuracy of the M&TE used for calibration and the readability or resolution of the M&TE devices. When ALT is used as one term in an uncertainty calculation the additional terms for M&TE accuracy and M&TE readability do not have to be repeated or included. Power supply Effects (PS) The changes in a loop instrument's accuracy due to changes in the voltage supplied to the device from the loop power supply. Vendors commonly express power supply effect in one of two ways. The most common expression is a +/-percent span per volt of variation in power supplyvoltage. The second most common expression is a +/- error band assuming a certain maximum variation in power supply voltage. By dividing the error by the magnitude of the assumed voltage variation in this specification, the form of this type of specification becomes a +/- percent span per volt of variation as well.

NOTE: Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 15 of 36 Care must be taken to ensure that the power supply effect specified is applied to the correct power supply. In some cases, an instrument loop may contain devices which are powered by 120 VAC sources, even though the loop signal is powered from a DC power supply. The equation for determining the device power supply effect is as follows: (Equation Vl-4) PS= (V) (VPE) where: V = Power Supply Voltage Variation (Volts) VPE = vendor's power supply effect expression (%CS/Volt) Power supply effect is generally considered to be a random independent uncertainty. For all Rosemount series 3150 transmitters the published Power Supply Effect specification statistical content is considered to be +/-3cr (See Rosemount Industry Letter - Attachment 2). Therefore, the published Power Supply Effect specification may be multiplied by 2/3 to match other 2cr uncertainties. H. Temperature Effects (T) The change in a loop instrument's accuracy due to changes in ambient temperature in the loop instrument's environment relative to calibration conditions. Normal and accident temperature effects are considered separately. Normal temperature effect (Tn) deals with only the effects in changes of temperature from calibration to the normal, reasonable maximum or minimum for a given environment. This uncertainty will not be used in the accident loop uncertainty calculation. Accident temperature effects (Ta) deal with the temperature effects from the calibration temperature to the postulated temperature during an accident. Accident temperature effects need not be considered for temperature levels which occur after the loop's required function in the accident scenario. Generally, this uncertainty includes accident humidity, pressure, and chemical spray effects. Specific Environmental Qualification Documentation Packages should be consulted as necessary. Normal temperature effects are determined by multiplying the change in temperature by the instrument vendors expression for temperature effect. (Equation Vl-5) Maximum of either; Tn = (Nmax-TC) (VTEN) or Tn = (Tc-Nmin) (VTEN) where: VTEN = vendor's normal temperature effects expression (%CS/ °F) Nmax = maximum normal temperature (°F)

Instrument Setpoint Methodology Nm;n = minimum normal temperature (°F) Tc = calibration temperature (°F) IC-3.17 Rev. 8 Page 16 of 36 Note: Due to the prevalence of warmer temperatures in South Florida, it is generally appropriate to utilize the Nmax value in the uncertainty calculation. Accident temperature effects are generally expressed as a percentage of span for the tested condition in Environmental Qualification (EQ) test reports. Generally, if the tested conditions envelope that which will be seen by the instrument, the specified limits of uncertainty should be used. If this uncertainty is unacceptably high, the temperature effects for levels greater than those which occur after the loops required function in the accident scenario need not be considered. Accident temperature effect as specified by the manufacturer generally envelope the normal temperature effect since it is the total uncertainty observed during the tested scenario. Therefore, it is not necessary, in these cases, to include normal temperature effect into the accident loop uncertainty equation. If separate terms are specified for accident pressure, humidity, and chemical spray, these terms should be combined into an accident temperature effect by the following method. (Equation Vl-6) where: VTE(a) = vendors accident temperature effect (%CS) HU(a) = accident humidity effect (%CS) P(al = accident pressure effect (%CS) CSE(a) = accident chemical spray effect (%CS) If an instrument is located inside an enclosure (cabinet), the ambient temperature assumed should consider conditions inside the enclosure. Generally, temperature effects are considered random, independent uncertainties unless otherwise determined or indicated by the manufacturer. Rosemount Note: Some vendors have specific restrictions on the application of the equipment temperature effect. One such restriction is applicable to Rosemount model 3154 pressure transmitters. In VTM 8770-9834 REV. 23, Rosemount provides a Table titled "Temperature Effect" which provides the formulae for application of the effect for all range codes of the 3154 transmitters. Under the Table there is a sentence which reads: "This specification may be linearly interpolated down to 50°F (27.8°C) temperature interval." The meaning of this note is that the minimum temperature interval applied from calibration temperature to normal, maximum operating temperature is 50°F. Above that minimum the temperature effect is linearly proportional.

I. Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 17 of 36 In addition, for all Rosemount series 3150 transmitters the published Ambient Temperature Effect specification statistical content is considered to be +/-3a (See Rosemount Industry Letter - Attachment 2). Therefore, the published ambient temperature effect specification may be multiplied by 2/3 to match other 2a uncertainties. Humidity Effects (HU) The HU effect is the change in a loop instrument's input/output relationship due to the ambient humidity in the loop instrument's environment. This parameter is seldom specified. When specified, humidity effect will be expressed as a percentage over a particular humidity range. If this humidity range envelopes the normal environmental conditions, this percent uncertainty should be used. Humidity effects are generally considered to be random, independent uncertainties. Accident humidity effects should be included with accident temperature effects. J. Radiation Effects (R) K. The change in a loop instrument's input/output relationship due to the effects of ionizing radiation. Normal and accident radiation effects are considered separately. Normal radiation effect (Rn) deals with only the effects of the radiation dosage received at normal radiation dose rates. Accident radiation effects (Ra) deals with the effects of the postulated total integrated dose (normal dose plus dose received during postulated accident). Accident radiation effects need not be considered for total integrated dose levels greater than those which occur after the loop's required function in the accident scenario. Vendors generally specify radiation effects as an uncertainty based on a tested radiation dose. Due to the nature of this uncertainty, interpolation between test points should not be performed without a defendable basis. The uncertainty measured at a test point which envelopes the required environment should be used. Normal versus accident effects would be determined based on the doses received in the environment of the device. Normal radiation effects will be used to calculate the total loop uncertainty for normal operating conditions. Accident radiation effects will be used to calculate total loop uncertainties for accident conditions. Both of these terms are generally considered to be random, independent uncertainties unless otherwise indicated by the manufacturer. Seismic Effect (S) The changes in the input/output relationship of a loop instrument due to seismic activity. Determination of seismic effects must consider the actual seismic response due to the instrument location (building and elevation). If the instrument is installed in a racl< or panel, the seismic effects should include the racl< or panel's seismic response. Vendors normally supply a certain seismic performance specification for tested seismic conditions. The uncertainty should not be interpolated, but used as is, if the tested spectrum

L. Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 18 of 36 envelopes the required environment. Deviation from this method requires a defendable basis. Design Basis Accidents (DBA's) concurrent with Safe Shutdown Earthquakes (SSE's) are not considered credible. That is, it is not considered probable that both an SSE and a DBA would occur at the same time. This allows the seismic effects to be eliminated from most error analyses since accident condition effects generally create the larger errors for a loop. The seismic effect would only be included if a loop has specific functional requirements that must be met during or after an SSE, but not during or after a OBA, or if SSE is greater than OBA, (common in outside environment), unless a defendable bases is provided to the contrary. Seismic effects are generally considered to be random, independent uncertainties unless otherwise indicated by the manufacturer. Static Pressure Effect (SPE) The uncertainty associated with the change in the input/output relationship of a differential pressure device due to calibrating the device at a different static pressure than the static pressure at which it is operated. Static pressure effect need not be considered for any devices other than those in direct contact with the process. Some manufacturers specify SPE in terms of basic accuracy changes while others, (e.g. Rosemount transmitters), indicate changes in both a transmitter zero and calibration span parameters. Care must be taken when determining the total SPE. A review of the manufacturer's specifications and the plant calibration procedures may be required. This is evident with Rosemount transmitters where Rosemount states, for example for model 1154 series, that the span effect is systematic and can be calibrated out and if "calibrated out", a correction uncertainty of +/-0.5% reading/1000 psi would remain. If it is determined that the span effect is not "calibrated out", then an additional systematic bias uncertainty may be required. The form of the expression for SPEz, the static pressure zero effect, and SPEs, the static pressure span effect, is normally defined in general equations as follows: (Equation Vl-7) SPEz = (VSPEz) (P) SPEs = (VSPEs) (P) where: VSPEz = vendor's zero static pressure effect uncertainty expression (%CS/psi) VSPEs = vendor's span static pressure effect uncertainty expression (%CS/psi) P = operating static pressure of the device (psi) The Nuclear Industry has questioned the application of Static Pressure Effects in differential pressure transmitters model 315X series provided by Rosemount/Emerson. Care must be exercised in the application of the Rosemount performance specifications for model 315X

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 19 of 36 differential pressure transmitters when considering these effects. The high static line pressure zero effect can be calibrated out by the customer (see 3150 Series Reference Manual 00809-0100-4835 for additional information). If it is not calibrated out, the error associated with the High Static Line Pressure Zero Effect is as follows for high static line pressure (Ps) less than or equal to 2000 psi (13.79 MPa): High Static Line Pressure Zero Effects Range Code High Statics Line Pressure Zero Effect Ps :< than 2000 psi 1 +/-0.25% URL per 1000 psi 2-5 +/-0.1 URL per 1000 psi This specification may be linearly interpolated in 1000 psi (6.89 MPa) increments. The note below the Table above has been interpreted to mean that the static pressure effect is treated in 1000 psi increments meaning if the static pressure were anywhere less than 1000 psi the full increment of 1000 psi must be applied. If the static pressure were greater than 1000 psi then the increment to 2000 psi would be applied. See the Rosemount Reference Manual for static pressures greater than 2000 psi that have also been treated in 1000 psi increments or steps. The application of the Rosemount specification has been clarified by an Emerson/ Rosemount Industry letter (see Attachment 1 ). In this letter it states: "As it relates to interpolation of the 3150 zero effect specification, we know the zero effect is not systemic and not fully linear over line pressure. This is especially true for low line pressures below 500 psi, as a linear interpolation (or reduction) of the uncertainty specification can become less conservative." "That said, for calculations of error involving line pressure ~500 psi, a linear interpolation would remain conservative based on our available data. Therefore, the following are acceptable approaches to addressing static line pressure zero effect:" "- For static line pressure::;; 500 psi, linear interpolation of the static line pressure zero effect specification in 500 psi intervals." There is no interpolation for static pressure less than or equal to 500 psi. "- For static line pressures> 500 psi & < 1000 psi, linear interpolation of the static line pressure zero effect specification between 500 psi & 1000 psi intervals." Linear interpolation is permitted for static line pressure between 500 & 1000 psi. - For static line pressures 2: 1000 psi & ::;; the static pressure limit, linear interpolation of the static line pressure zero effect specification in 1000 psi intervals." Linear interpolation is permitted for static line pressure between1000 & the static pressure limit. The Rosemount Reference Manual, in the section titled "High Static Line Pressure Span Effect," has tables describing uncertainties related to high static line pressure span effect. These have notations about "per 1000 psi" but do not have a note similar to "in 1000 psi increments". In the Rosemount Reference Manual, it is stated that "Rosemount 3150 Series

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 20 of 36 Range 1, 2, and 3 differential pressure transmitters do not require correction for high static pressure span effect. The correction for these ranges occurs within the sensor. But "Rosemount 3150 series Range 4 and 5 pressure transmitters experience a systematic span shift when operated at high static line pressure. It is linear and correctable during calibration." The span effect for ranges 1, 2, and 3 are corrected within the sensor, but still have some error; and for ranges 4 and 5 can be corrected during calibration. For Static Line Pressure Span Effects there is a similar Table that provides the method for error determination: High Static Line Pressure Span Effect 3154ND Ranges 1, 2 and 3: Range Code High Static Line Pressure Span Effect per 1000 psi 1 +/-(0.4% URL+ 0.40% span) 2-3 +/-(0.1 % URL+ 0.1 o/o span) This span error has also been treated in 1000 psi increments. The High Static Pressure Span effects are also addressed by the Emerson/Rosemount Industry letter (see Attachment 1) which clarifies the application of the span error effect as follows: "Regarding interpolation of the static line pressure span effect specifications of pressure range codes 1, 2, and 3, the published specification may be linearly interpolated for line pressures ~500 psi and~ the static pressure limit in the same manner as the zero effect specification. For pressure ranges 4 and 5, correction for the systemic span shift should be performed during calibration as outlined in section 3 of the 3150 Series Reference Manual 00809-0100-4835. Interpolation of the remaining span correction uncertainty is the approved method for all line pressures" (~500 psi). The Total Static Pressure Effects are obtained as follows: (Equation Vl-8) (If the effects are random, independent) SPE = ((SPEz)2 + (SPEs)2) 1/2 (Equation Vl-8) (If the effects are biases or dependent) SPE = SPEz + SPEs In addition, for all Rosemount series 3150 transmitters the published Static Pressure Effect specifications statistical content for both zero and span are considered to be +/-3a (See Rosemount Industry Letter - Attachment 2). Therefore, the published Static Pressure Effect specification may be multiplied by 2/3 to match other 2a uncertainties.

M. N. VII. Instrument Setpoint Methodology Overpressure Effect IC-3.17 Rev. 8 Page 21 of 36 The overpressure effect accounts for errors in a transmitter's performance after exposure to process pressures in excess of its normal design range. In general, the overpressure effect is not required to be included in loop error analysis. Most loops are designed to operate within their worst-case process conditions, which include the worst-case process pressure. However, if it is determined that overpressure has not been accounted for and could occur, then overpressure effect should be calculated, following the vendors stated effect, and included in the device's accuracy term. Overpressure effect is generally considered to be a random uncertainty term unless otherwise indicated by the manufacturer. In addition, for all Rosemount series 3150 transmitters the published Overpressure Effect specification statistical content is considered to be +/-3cr (See Rosemount Industry Letter - ). Therefore, the published Overpressure Effect specification may be multiplied by 2/3 to match other 2cr uncertainties. Readability/Resolution (RES) Resolution or readability uncertainty refers to the error introduced by a technician in reading a calibration instrument and the indicator itself if applicable or the operator reading a plant instrument. Unless scale markings are very sparse, for analog indications, readability is defined as +/- one half the magnitude of a minor division on the indicator scale. For digital indications, readability is defined as+/- one least significant digit of indicated value. The RES uncertainty during calibration is accounted for by M&TE (see Sec VI). The RES uncertainty in reading a plant indicator should be incorporated, if appropriate, into the calculation for device indication uncertainty. OTHER SOURCES OF UNCERTAINTY There are additional sources of uncertainty which are not due to instrumentation but do affect the loop's uncertainty. A. Process considerations (PC) Process considerations deal with the physical changes which occur to the plant's process systems due to normal and accident conditions. There is no limit to the number of dependent or independent process considerations which can affect a particular measurement. Reference leg heatup, process density changes, thermal stratification and dimensional changes of system components (tank expansion) are examples of process considerations. These considerations produce uncertainties which must be evaluated for inclusion in the loop uncertainty calculations under the conditions for which the loop must function. Typical process considerations for a level transmitter might include: field measurement uncertainties for condensate pot elevation, (wet leg configuration only).

B. Instrument Setpoint Methodology differences between as built vs. nominal tap differentials. IC-3.17 Rev. 8 Page 22 of 36 changes in reference leg or operating temperatures, relative to the base reference calibration. specific gravity errors for fluid density variations due to variations in PPM boron concentration, temperature, constituent concentrations, etc. static head (dead-leg) on transmitter. flow impingement on measured level or differential level, relative to reference calibration. effects of variations in pressure blanket (nitrogen, steam, hydrogen, etc.). vaporization of wet reference leg during extreme accident temperatures. Process considerations can be random or bias terms depending on the nature of the uncertainty itself and the assumed ranges of conditions. Primary Element Uncertainties (PU) Primary Element Uncertainty deals with the accuracy of a component, piece of equipment, or installation used as a primary element to obtain a given process measurement. Examples are orifice plate erosion, the accuracy of a flow nozzle and/or the accuracy achievable in a specific flowmeter run. C. Insulation Resistance (IR) Insulation resistance effects (IR) are the uncertainties introduced into the loop measurement of a parameter due to the degradation of the cable insulation resistance during accident conditions. Therefore, IR effects are only considered credible during an accident environment. Since the IR error generally has a definitive effect on instrument performance, it is considered a bias error and as such is algebraically added to a loop uncertainty, unless it can be demonstrated otherwise. The calculations in EQ Doc Pacs 1000 (St. Lucie) & 1001 (Turkey Point) establish an acceptable maximum leakage current of 0.04 mA for a current loop required to function during and after an accident. This is 1 % of the low end (4 mA) of the measured span and equates to 0.25% of span as follows: (Equation Vll-1) IR%span = (IRMaxleak/Cal Span) (100) = ((0.04) I (20-4)) (100) = 0.25% Cal Span Therefore, for use in instrumentation uncertainty calculations, the IR error is 0.25% of instrument loop span. If a particular error analysis cannot accept this worst-case bias error, or the loop is not a current loop, or the actual conditions exceed those assumed in the

D. Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 23 of 36 calculations in the EQ Doc Pacs, then a loop specific IR error evaluation should be performed. Channel Noise (N) Noise is a catch-all category used to account for the effects of radio frequency interference (RFI}, electro-magnetic interference (EMI} and process induced channel noise. All three of these phenomena introduce a cyclic signal on top of the instrument channel signal which tends to obscure the process signal resulting in a signal "band" rather than a clean process signal. Noise is not a condition which can be predicted by the design organization. In fact, steps are normally taken to eliminate noise by using shielded and grounded instrument cables, routing instrument cables away from power cables and using good engineering practices during the design of instrument installations. The result of channel noise can always be considered conservative since it tends to reduce the available margin between the process signal and a setpoint. Therefore, channel noise will not be considered by this methodology. VIII. SETPOINJ DETERMINATION An allowance shall be provided between the trip setpoint and the Analytical Limit to ensure a trip before the Analytical Limit is reached. The allowance shall account for all applicable design basis events and the process instrument uncertainties unless they were included in the determination of the Analytical Limit. Figure Vlll-1 illustrates the relationships between the trip setpoint and other parameters. Region A represents the uncertainties allowed between the analytical limit and the trip setpoint. Region B denotes the difference between the allowable value and the trip setpoint. Region D illustrates the difference between the expected value of the process variable during normal operation and the trip setpoint. Region E notes an allowance for calibration setting tolerance or as-left tolerance about the trip setpoint. Setpoint determination is dependent on values established by analyses which are beyond the scope of the setpoint methodology. Specifically, Safety Limit (SL} and Analytical Limits (AL} were established during the design of the facility. The values of these terms can be found in a number of places, including specific accident analysis calculations, Chapter 15 of the UFSAR and Technical Specifications, (note that the values in the Technical Specifications may be either Al's or setpoints or both}. In addition, the Technical Requirements Manual for each plant may contain setpoints or limits for which setpoint allowance calculations can be appropriate. It is assumed by this methodology that the Analytical Limit represents the true process parameter value at which plant corrective action is initiated in the accident analysis. (No instrument uncertainty margin is assumed within this value by the setpoint methodology.} Finally, it is assumed that adequate response time was considered in the accident analysis. To determine the setpoint, the device uncertainties, process uncertainties, primary element uncertainties and biases must be combined into a Total Loop Uncertainty (TLU) or Region A, as described in the following sections.

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 24 of 36 A thorough sanity check of the determined setpoint and the designated setting tolerance (Region E) should be performed to assure that the possibilities of inadvertent actuation or nuisance alarms will not occur. The following equations assume a multiple device instrument loop with no transfer functions or with linear transfer functions with a unity gain. Refer to ISA Standard Practice 67.04 Part II for a list and use of equations for propagation of input uncertainties through transfer function modules. A. B. C. Device Uncertainties (DU) The individual device random uncertainties are in themselves a statistical combination of uncertainties. Depending on the type of device, its location, and the specific factors that can affect its accuracy, the determination of the device uncertainties will vary. The device uncertainty may be calculated with the following general equation: (Equation Vlll-1) where: A, D, TE, R, S, HU, RES, ST, SPE, PS, M, & Bare as defined in Section VI. Process Allowance (PC) The allowance of Region B (see Figure Vlll-1) shall consider all the effects of independent process considerations (PC) on the instrument loop's uncertainty. As discussed previously (see Other Sources of Uncertainty in Section VII), the number of process considerations and the manner in which they may affect a loop's uncertainty is virtually limitless. As with all other independent sources of uncertainty, independent process considerations (PC) are squared then added: (Equation Vlll-2) PC= PC/+ PC/+... + PC/ Dependent process considerations (PC) are added to the coincident effect then squared. Non-random process considerations (PC) are simply added (or subtracted depending on the nature of the uncertainty) to the result of the SRSS computation of TLU. Primary Element Uncertainties (PU) The effect of all independent primary uncertainties (PU) on the instrument loop's uncertainty. As with all other independent sources of uncertainty, independent primary uncertainties (PU) are squared then added: (Equation Vlll-3) PU = PU/+ PU/ +... + PU/

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 25 of 36 Dependent primary uncertainties (PU) are added to the coincident effect then squared. Non-random primary uncertainties (PU) are simply added (or subtracted depending on the nature of the uncertainty) to the result of the SRSS computation of TLU. D. Total Loop Uncertainty (TLU) Equation E. F. The Total Loop Uncertainty is the SRSS combination of all the appropriate uncertainties as follows: (Equation Vlll-4) +/- TLU = +/- (PC2 + PU2 + DU/ + DUn./ +... + DU/) 1/2 +/- B where: PC = Process Allowance PU = Primary Element Uncertainties DUn = n number of Device Uncertainties B = Appropriate Biases Setpoiot Value Equations for BPS & ESFAS Functions The setpoint value determination is performed for high limits based on Figure Vlll-1. The equations governing these determinations are as follows: (Equation Vlll-5) SP= AL-TLU* where: SP AL TLU* = Nominal Setpoint = Analytical Limit = Absolute value of the Negative Component of Total Loop Uncertainty For low limit setpoints, the following equations apply: (Equation Vlll-6) SP= AL+ TLU+ where: TLU+ = Absolute value of the Positive Component of Total Loop Uncertainty Allowable Value Equations tor BPS & ES FAS Functions The Allowable Value is required when specified in plant Technical Specifications, (usually for reactor protection and safety features actuation systems), or other design basis documents. It is used by the plant to verify performance and operability at prescribed surveillance intervals. The uncertainties included in the allowance between the allowable value and the trip setpoint (see Region B of Figure Vlll-1) are a function of the portion of the instrument channel being tested and this setpoint calculation methodology.

G. Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 26 of 36 The determination of the allowance forthe Allowable Value, for that portion of the instrument channel periodically tested will be composed of the errors that could be present during the surveillance such as Reference Accuracy (A), Measurement and Test Equipment M&TE error, M&TE readability error, projected drift (D), the setting tolerance from the previous calibration (ST), and other uncertainties that could be present, i.,e., are measurable, during calibration. The inclusion of additional uncertainties may be acceptable but must be justified in the calculation. Only those uncertainties associated with events or conditions expected to cause changes that would be measurable during the periodic surveillances should be included. Excluding any of these parameters from the allowance is conservative. For example, excluding normal temperature effect from the determination of Allowable Value is conservative since normal temperature extremes are usually not present during calibration. The following equations are written to only include reference accuracy, drift, setting tolerance, M&TE and M&TE resolution. Since this would be conservative, (i.e. excluding instrument uncertainties during normal operation), the methodology of determining the Nominal Setpoint (SP), using TLU and then subtracting the allowance for Allowable Value, is acceptable. The allowable value determination is performed for high limits based on Figure Vlll-1. (Equation Vlll-7) where: AV = Allowable Value ANLu = Sum of the squares of the reference accuracy terms for only the equipment being periodically tested STNLu = Sum of the squares of the setting tolerance terms for only the equipment being periodically tested DNLu = Sum of the squares of drift terms for only the equipment being periodically tested MNLu = Sum of the squares of the M&TE terms, for only the equipment being periodically tested RESNLu = Sum of the squares of the RES terms, for only the equipment being periodically tested Note: The drift terms used in above equation should only account for the interval between successive surveillance periods. For low limits, the following equation applies: (Equation Vlll-8) Setpoint Equations for Non-RPS, ES FAS Functions For non-RPS, ESFAS setpoints and non-safety setpoints; safety limits, analytical limits, and allowable values may not exist. However, Process Limits (PL) often directly replace analytical

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 27 of 36 limits in the equations, and allowable values (here called Operational Limits (OL) to differentiate these from safety-related setpoint applications) may be desired to confirm operability of the instrumentation. Therefore, the following equation exists for high limit setpoints. (Equations Vlll-9) SP= PL-TLLJ* For low limit setpoints, the following equation applies for non-safety loops. (Equation Vlll-10) SP= PL+ TLU+ If applicable, the high limit OL is determined with the following equation. (Equation Vlll-11) For low limit setpoints. (Equation Vlll-12) OL = SP - (ANLU + DNLU + ST NLU + MNLU + RESNLU) 1/2 H. As-Found Tolerance (AFT) I. The AFT for either a loop or individual instrument will be provided by Reference 7. However, there will be cases where those values are not available from the Reference and will have to be calculated from error values present during and between calibrations. The equation for the AFT for an individual device is: (Equation Vlll-13) AFT;nstr = (A2+ D2 + M2 + RES2 + ST2) 112 The AFT Loop is the SRSS of the instruments that are calibrated together. The equation for the AFT of a loop is the SRSS of the Equation Vlll-13 of the individual devices in the loop. The AFT is NOT included in the in the calculation of the DU or TLU but is a value that should be calculated or taken from the Reference with results documented in the calculation results. BG 1.97 variables and Indication Only Loops This methodology has been written specifically for the calculation of setpoints. Although indication is not a setpoint, the methods outlined in this document are applicable to determining the accuracy of an indication loop if called upon to do so.

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 28 of 36 Indication only loops will not have associated setpoints or allowable values. Therefore, total loop uncertainties for the environments in which these loops must function are all that is required. These calculations shall consider normal operating conditions, seismic conditions, and design basis accident (DBA) conditions as necessary.

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 29 of 36 Figure is intended to provide relative position for high-going setpoint. Analytical Limit C A B I D Normal Operating Level A. Allowance for Total Loop Uncertainty orTLU B. Allowance Normal, measurable Loop Uncertainty or NLU C. Region where channel may be determined inoperable D. Plant operating margin E. Region of calibration setting tolerance or As-Left Tolerance Figure Vlll-1 Allowable Value or As-Found Tolerance Nominal Setpoint

Instrument Setpoint Methodology IX. DATA TO PERFORM INSTRUMENT LOOP ERROR CALCULATIONS IC-3.17 Rev. 8 Page 30 of 36 To ensure consistency of the instrument loop error calculations it is important that the data sets are consistent in scope and content. This section specifies the scope of data generally needed to perform instrument loop error calculations. Required data: Loop data; Loop identification no. Loop function and requirements Loop diagram (simplified) Reference drawings (P&ID, elementaries, schematics) Power supply (distribution system) Instrument list (tag nos.) IR effects Process considerations Instrument data (listed by tag no.): Manufacturer Model no. Location Calibrated input range Calibrated output range Calibration procedure no. Vendor data (listed by manufacturer/model no.): Accuracy Drift (algorithms) Temperature effects (algorithms) Humidity effect (algorithm) Radiation effects (algorithms) Power supply effect (algorithm) Static pressure effect (algorithm) Seismic effect (algorithm) Max. span capability Minor division or least significant digit value (for indicating devices only) Location data (listed by room): Seismic response, frequency and acceleration Environmental conditions (normal and accident) Temperature Humidity Radiation Calibration procedure data (listed by procedure): Calibration procedure no. Calibration frequency/ Setting tolerance Test instruments/accuracy Loop instrumentation required accuracy

X. SOURCES OF DATA Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 31 of 36 This section cannot provide a definitive list of all the possible sources of data. Rather, this section will provide suggestions as to where the necessary data may be found. Since the instrument loop error calculations will become part of the facility's design basis for instrument loops which perform safety related functions, it is important that the sources of data do not jeopardize the validity of the calculation. Collected data must be backed up with references to design documents or fully developed assumptions. Data collection is by far the most difficult step in developing instrument loop error calculations. Care and attention to detail are essential if the results are to be worthy of the effort. Loop Data (collected for each instrument loop) Data for this group should all be available from documents such as the system piping and instrument diagrams, connection wiring diagrams, and electrical schematics. Loop function description should be available from either the system description or, in the case of safety related loops, Chapter 7 of the FSAR. Instrument Data (collected for each instrument) Data for this group should be readily available from vendor technical manuals and/or instrument calibration records. Additional sources such as purchase order/specifications, performance specifications, instrument location and installation drawings should prove helpful. Vendor Data (collected for each discrete manufacturer/model no. combination) The first source which should be checked are the sets of data collected by previous instrument loop error calculations. Since this data is generic to a specific manufacturer model number, all calculations for loops which use the same instruments should use the same data or give specific reasons for not doing so. In the absence of existing data from previous calculations, vendor publications, equipment qualification reports and instrument purchase specifications are all good sources of information. In cases which no data can be found, communication with the instrument manufacturer often proves fruitful. As a last resort a value may be assumed based on the performance of similar instruments by other manufacturers. Recently, several of the larger testing laboratories have begun offering replacement instruments for discontinued units which have been demonstrated to meet original specifications. This implies that the labs may have data on old, discontinued instruments. Location Data The information for this group pertains to the environmental regions within the plant. As for vendor data, the data sets used for previous calculations should be checked first. If available these data sets should be used, or specific reasons given for not using them.

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 32 of 36 Discussions of normal temperature and humidity levels should be available in system descriptions, FSAR, performance specifications or possibly the technical specifications. Plant operator logs could also prove helpful in defining the normal ranges. Accident temperature and humidity levels should be available in the accident analysis (FSAR Chapter

15) and may be available in EQ Doc Pacs.

Radiation zone maps and plant records should provide the necessary information for both normal and accident dose rates. Seismic response information should be available in Chapter 3 of the FSAR. Otherwise, the original civil calculations done by the A/E will need to be consulted. For all location data, if the instrument is located inside a rack or panel the data must represent the environmental and seismic conditions inside. Calibration Data With the exception of required accuracy, all data from this group will be available from the calibration procedures. Required accuracy refers to the minimum accuracy assumed when the loop was designed. If this is to be found it will almost certainly be in the vendor's performance specifications. This may include the NSSS vendor, A/E, and major component manufacturers (i.e., turbine vendor, pump vendors, etc.). If no value can be found the accuracy of the installed instrument will be assumed to be the required accuracy.

XI. Instrument Setpoint Methodology INSTRUMENT SETPOINT CALCULATION FORMAT IC-3.17 Rev. 8 Page 33 of 36 The format of a setpoint calculation should essentially follow that which is described in Reference 8, Procedure EN-AA-100-1004, Rev 11, "Calculations." The specific format presented below is a proven method of presenting and calculating instrument setpoints and is the suggested format for use in future setpoint calculations. Cover Sheet ii List of Effective Pages iii Table of Contents 1.0 Purpose/Scope 1.1 Purpose The purpose should contain a clear, concise statement of the objective of the calculation and a brief description of the plant processes monitored by the loops being analyzed. 1.2 Scope The scope should address the specific unit, system and identify by instrument tag number the specific instrument devices included in the evaluation. A simple block diagram of the evaluated loop should also be included in this section. 2.0 References All reference material including drawings, codes, standards and vendor information such as catalog cut sheets, reports, etc. shall be listed. Revision of the document should be included. Where references are not considered easily retrievable, i.e. Non-QA Records, the references should be included as an attachment. 3.0 Methodology This section should refer to the use of the combination of statistical and algebraic methods as described in the Instrument setpoint Methodology Standard IC-3.17. Also provide any special clarification or information about the calculation method used. 4.0 Assumptions/Bases 4.1 Assumptions This section should contain all assumptions and judgments used in the calculation. Assumptions are normally made when specific data is not available or in lieu of a rigorous analysis and should be kept to a minimum. A basis for the assumption or judgment, which can be verified by an independent reviewer, must also be provided.

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 34 of 36 "Engineering Judgement" should be used as a basis only as a last resort. Refer to procedure EN-AA-100-1004, "Calculations" for restrictions on the use of "Engineering Judgement". 4.2 Bases Provide a brief functional description of the loop being analyzed. The description should include all known conditions or values from codes and standards, measured data, functional requirements, (alarm, control, indication) and design conditions. Be specific about when the various functions are required (i.e. normal operation, post-accident, shutdown). 5.0 Calculation 5.1 Environmental Data This section should list, preferably in table format, the applicable environmental conditions used for the calculation. (For St. Lucie, the values in the section will generally be obtained from the St. Lucie environmental parameters calculation PSL-BFJl-92-003). 5.2 Instrument Uncertainties This section should list all appropriate error effects for each device. It is also recommended that error effects that are not applicable for that specific device be listed as "N/A". Each uncertainty element (i.e. accuracy, drift, temperature effect, etc.) shall be calculated for each device in this section. Any Process Allowances and Primary Element Uncertainties shall also be listed in this section. 5.3 Total Loop Uncertainty This section shall describe and show the general equation used to determine the Total Loop Uncertainty (TLU). The preferred format for displaying the determination of TLU is a table listing each element of uncertainty for each device along with their respective totals which is then combined using the displayed general equation into aTLU. 5.4 Setpoint Evaluation This section should determine the proper setpoint by combining the calculated uncertainties with the analytical limit. A brief description evaluating the acceptability of the setpoint should be included. 6.0 Results 6.1 Instrument Setpoint Results This section should contain a summary of the calculation. It is acceptable to refer to the pages where the results are presented rather than repeating them. Results must

Instrument Setpoint Methodology IC-3.17 Rev. 8 Page 35 of 36 include pertinent values related to each of the objectives listed in the Purpose section. 6.2 Calibration Requirements This section should include the calibration and scaling information related to the instrument loop. The calibration span, setting tolerance of the tested instrument, and the as-found tolerance of the instrument should be included in this section. Including the calibration information as a part of the setpoint calculation will help to preclude disagreements between plant maintenance and engineering practices. 6.3 Attachments All instrument data sheets and other relevant information which supports the instrument uncertainty calculation should be included as an attachment with the exception of information that is readily available in Document Management Systems such as NAMS, etc. Such exception documents do not need to be included as attachments.

Instrument Setpoint Methodology XII. References IC-3.17 Rev. 8 Page 36 of 36

1. Regulatory Guide 1.105 Revision 3,

"Setpoints for Safety-Related lnstru mentation."

2. ISA-S67.04 Part 1,

1994, "Setpoints for Nuclear Safety-Related lnstru mentation."

3. STD-IC-3.19 Revision 0, "Design Standard for Analysis of Instrument Drift Data"

4. ISA RP67.04 Part 11, September 1994, Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation

5. EPRI Technical Report 3002002556 Revision 2, "Guidelines for Instrument Calibration Extension/Reduction -

Statistical Analysis of Instrument Calibration Data"

6. Generic Letter 91-04 dated April 2, 1991, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle

7. FRAM-00012-REPT-005 Rev O "St. Lucie Nuclear Power Plant Units 1 & 2, 24-Month Fuel Cycle Project, Drift Analysis Summary Report"

8. Procedure EN-AA-100-1004, Rev 11, "Calculations"

9. Emerson/Rosemount Letter from Tanner Clink to Industry dated 08/12/2024 "3150 Series High Static Line Pressure Specifications" (Attachment 1) 1 0.

Emerson/Rosemount Letter to Industry dated 11/16/2018 "Rosemount 3150 Series Nuclear Pressure Transmitter Performance Specifications" (Attachment 2)

Instrument Setpoint Methodology Appendix A ST. LUCIE SETPOINT PROGRAM PLAN, SPECIFIC GUIDELINES/ASSUMPTIONS AND AS-FOUND/AS-LEFT GUIDELINES IC-3.17 Rev. 8 Page A1 This appendix describes the specific St. Lucie Setpoint Program and provides standard guidelines and assumptions specific to the St. Lucie Plant. Instrument uncertainty and setpoint calculations are to be performed in accordance with the guidelines presented in this appendix as well as those presented in the main body of this methodology. Also, in addition to those in the main body, St. Lucie specific standard assumptions are included which are available for use in setpoint calculations. These assumptions are considered conservative and are intended to reflect actual plant practices. The use of these assumptions provides both a standardized approach and a means of minimizing redundant effort. Additionally, guidelines are provided for determining the as-found/as-left tolerances and for determining the as-found acceptance criteria that can be applied during calibrations. Two examples are provided illustrating the calculation of the various uncertainties and acceptance criteria.

Instrument Setpoint Methodology Appendix A PROGRAM PLAN IC-3.17 Rev. 8 PageA2 At St. Lucie, a formal program for addressing and evaluating instrument setpoints has been established. Setpoints are classified according to six control classes described in the St. Lucie Units 1 & 2 Setpoint List, 8770-B-470 and 2998-B-470 respectively. Based on significance to plant safety, these classifications determine the appropriate level of analysis and documentation necessary for each individual setpoint. The control classes are listed below. These control classes are equally applicable to automatic setpoint functions and those functions which are manually controlled via indication. Class 2 Description Setpoints that are part of the Reactor Protection System (RPS) and/or Engineered Safety Features Actuation System (ESFAS) as identified in the Technical Specifications (TS). Setpoints in Class 1 are the most important in terms of safety. These setpoints typically were established by the NSSS vendor using comprehensive uncertainty analyses. Setpoints in this class would require rigorous uncertainty calculations (or evaluation to substantiate the original analyses as bounding) to support and/or modify the setpoint. Setpoints that perform an active safety function, i.e. required to ensure integrity of the reactor coolant pressure boundary, to achieve and maintain safe shutdown, or to maintain offsite dose in accordance with 10CFR100 limits. Class 2 setpoints are relied upon forthe performance of safety functions, and can be grouped into two sub-classes: 2a) This sub-class includes setpoints for which an explicit magnitude is critical to the performance of a safety function. Setpoints in this sub-class would require rigorous uncertainty calculations ( or evaluation to substantiate the original analyses as bounding) to support and/or modify the setpoint. 2b) This sub-class includes setpoints relied upon to support the performance of an over-all system safety function which are based on nominal design values (i.e. analytical limits would not exist) and the precise magnitude is not critical to the ability of the over-all system to perform its safety function. Setpoints in this sub-class would typically not require uncertainty calculations and an evaluation/review commensurate with the application would be sufficient to support and/or modify the setpoint. The evaluation should substantiate the setpoint as a "nominal design value" and document that the precise magnitude is not critical for the performance of the over-all system safety function.

3 4 5 Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 PageA3 Setpoints that support TS requirements, i.e. typically required for maintaining the parameters associated with the safety analysis. These setpoints include any parameters addressed in the TS. Setpoints in Class 3 may be grouped into two sub-classes: 3a) This sub-class includes setpoints necessary to support the conclusions of the safety analysis and for which the safety analyses credited an explicit analytical value (i.e. SIT level, RWT low level, etc.). Setpoints in this sub-class would require uncertainty calculations (or evaluations which substantiate the original analyses as bounding) to support and/or modify the setpoint. If the safety analysis provides explicit allowances for instrument uncertainty, the setpoint may be the same as the Technical Specification value. If the safety analysis does not include an explicit instrument uncertainty allowance or the method of applying instrument uncertainty is not known for a particular case, the setpoint should be conservative to the Technical Specification value. 3b) This sub-class includes setpoints which are not directly necessary for maintaining safety analysis parameters, e.g. the diesel fuel oil seven-day storage requirement. This would include setpoints that represent nominal design values for which an analytical limit may not exist in a safety analysis and/or would not have a significant effect on the over-all system operation as credited in the analysis. Setpoints in this sub-class would typically not require uncertainty calculations, and an evaluation/review commensurate with the application would be sufficient to support and/or modify the setpoint. The evaluation should substantiate the setpoint as a "nominal design value" which would not significantly impact the analyses results, and/or that the conservatisms within the analyses would allot significant margin. Setpoints which are part of a discrete component associated with an overall system which is safety-related. All safety related instruments with setpoints that are not Class 1, 2, or 3. To support and/or modify setpoints in Class 4, an evaluation/review commensurate with the application would be sufficient. It is up to the user to provide the basis for the level of evaluation provided. With respect to non-safety related alarms, formal evaluation or calculation would not typically be required. Non-safety related setpoints that require consideration above that of Control Class 6 setpoints, typically non-safety related setpoints considered important to operation. Examples include setpoints which directly initiate plant, turbine, generator, or other major equipment actions or trips; impact plant personnel safety; require operator corrective actions; or protect against significant equipment damage or loss of power generation.

6 Instrument Setpoint Methodology Appendix A Remaining non-safety related setpoints. IC-3.17 Rev. 8 PageA4 Setpoints in Classes 5 and 6 do not require uncertainty calculations. Setpoints are established based on operating experience, good engineering practice, and/or vendor recommendations; therefore, a formal calculation or evaluation is not required. The instituted setpoint program at St. Lucie is to provide a design basis for each of the setpoints in Classes 1 through 4 in accordance with the above requirements. Setpoints in Class 1, the upper tier of Class 2 and the upper tier of Class 3 generally will have complete uncertainty calculations performed. Setpoints in the lower tier of Classes 2 and 3 and most of Class 4 generally will have evaluations showing that the actual setpoints are acceptable based on operating experience, good engineering practice, and/or vendor recommendations. SPECIFIC GUIDELINES/ASSUMPTIONS

1)

New instrument setpoints that require a setpoint calculation and that perform a safety related function or are required for Technical Specification compliance associated with FPL Nuclear Plants shall be developed on the graded approach basis of this standard with the exception of the Reactor Protection System (RPS) and Engineered Safety Features Actuation System (ESFAS) at St. Lucie Units 1 &2 which are established using the Westinghouse methodology described in WCAP-17504 for PSL. There are two RPS/ESFAS setpoints which are established based on this IC-3.17 methodology. They are the Loss of Load (Turbine Hydraulic Fluid Pressure-Low) [TS Table 3.3.1-1 Function 1 O] and RWT Level-Low [TS Table 3.3.3-1 Function 5.a].

2)

As documented in Reference 7, there has been significant statistical analysis of As-Found verses As-Left calibration data for safety-related instrumentation in St. Lucie Units 1 & 2. This significant effort provides basis for the extension of calibration intervals for many safety-related instrumentation and protective devices including RPS/ES FAS technical specification instrumentation. Statistically derived values for instrument drift are available for many manufacturer model number instruments in various groups (loops) and applications. The derived drift values are applicable to individual instruments and groups of instruments that are and have been calibrated singly or together. These statistically determined drift values are denoted by ADRAND drift. The error and uncertainty content in As-Found - As-Left (AFAL) calibration data is broader than traditionally defined drift. Each of the following sources of error can contribute to the magnitude of the AFAL drift value:

1. True drift representing a change, time-dependent or otherwise, in instrument/loop output over the period between any two consecutive calibrations.

2. Accuracy errors presented between any two consecutive calibrations.

3. Measurement and test equipment error between any two consecutive calibrations.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page AS

4. Personnel-induced or human-related variation or error between any two consecutive calibrations.

5. Normal temperature effects due to a difference in ambient temperature between any two consecutive calibrations.

6. Environmental effects on component performance, e.g., radiation, humidity, vibration, etc., between any two consecutive calibrations can cause a shift in component output.

7. Misapplication, improper installation, or other operating effects that affect component calibration between any two consecutive calibrations.

Many of the items listed above are not expected to have a significant effect on the measured AFAL settings. Due to the many independent parameters contributing to possible variance in calibration data, these independent parameters will all be considered together and is termed Analyzed Drift (ADRANo) uncertainty. In addition, the AFAL drift value can be used in place of more than just the drift term in the channel uncertainty calculation. For example, it may replace M&TE, Reference Accuracy and Drift in the interval between normal calibrations and could be used as a new as-found tolerance.

3)

For various reasons, electronic devices quite often do not have vendor specified drift uncertainties. The vendor may not believe that drift exists or the drift may be included in the accuracy statement. Another recommended source for drift is the drift data references mentioned in item 2) above. For those devices not included in the statistical analysis of historical calibration data, the preferred assumption is that drift is equal to the device accuracy value. This is a conservative method of accounting for instrument drift.

4)

The uncertainty for each of the M&TE instruments used to calibrate an instrument may generally be assumed to be equal to or better than the reference accuracy of the tested instrument. However, for those instruments that have been addressed by the analysis of calibration data and when that drift data is used, the actual specified M&TE accuracy used during calibration is usually included in the analysis of uncertainty in the ALT value. When the ALTgs19s values are used from the Reports or are calculated based on A, M&TE and RES terms, the M&TE, Accuracy, RES terms are not repeated in the calculation of TLU.

5)

In determining M&TE uncertainties for manufacturer model number instruments that have not been analyzed for statistically derived drift, the actual range of the test equipment being utilized must be determined. In order not to restrict plant practices, the assumption that the range of the test instrument is two times the calibrated span of the tested instrument will be utilized. This assumption has been agreed to as reasonable by appropriate plant l&C Maintenance and M&TE Shop representatives.

6)

Many conservatisms are used in the calculations performed for St. Lucie setpoints. These conservatisms may not appear in every calculation. This does not infer that those calculations, without the extra conservatisms, are not correct. Each calculation in itself must be defendable in accordance with this standard.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 PageA6 7} To provide uniformity and minimize redundant effort, consult environmental parameters calculation PSL-BFJl-92-003 for appropriate environmental values for use in instrument uncertainty analysis. 8} In cases where drift has not been derived from analysis of calibration data and a drift value is specified for an instrument for a period longer than the actual calibration interval, it may be reasonable to treat the drift specification as algebraically linear with respect to time. However, it is preferable to conservatively use the vendor's entire enveloping drift specification as the instrument's drift uncertainty. 9} For evaluation of vendor stated module power supply effect, AC loop power supply fluctuations may be conservatively assumed to be less than +/-10%, which represents typical equipment allowable voltage specifications. 1 O} For evaluation of vendor stated module power supply effect, DC loop power supply fluctuations may be conservatively assumed to be less than +/-5%, due to the inherent nature of precision DC power supplies. 11} Most instruments located in the RAB and RCB are effectively shielded from normal sources of radiation. As evidenced by the radiation zone maps in Chapter 12 of the FSAR, most instruments can be considered to be located in a mild environment during normal operating conditions. The frequent calibration of these instruments will also tend to correct any error due to normal radiation before appreciable effect is induced. For this reason, if it becomes necessary, it may be possible to justify not using the radiation values given in the environmental parameters calculation for a specific device. It is up to the user to provide the justification if radiation effect is to be considered negligible. 12} It is usually NOT reasonable to utilize the "single side of interest" reduction factor on a setpoint which only has either an increasing or decreasing setpoint direction. This is true because for the great majority of safety related instrumentation that has been analyzed for drift, the drift distributions were NOT normal, therefore the single side of interest factor is incorrect and not applicable. There may be some few cases in which there is a single side of interest, and the instrumentation was not included in the statistical analysis of drift for the surveillance interval extension project. For those few instruments in this category a single side of interest may be considered. However, this reduction factor of.823 (2 sigma uncertainty} should only be used in the rare cases where margin is at an absolute minimum. If used, the setpoint should be evaluated to assure that there is sufficient margin to account for the device uncertainties so that spurious alarms or normal process interference is avoided. Refer to ISA Recommended Practice 67.04 Part II for additional details of use. 13} The proper inclusion of accident (elevated temperature and radiation, etc.} and seismic effects for specific instrument loops can generally be accomplished using the following guidance: Instruments classified as Safety-Related, Seismic Category I, necessary for Safe Shutdown, must consider the greater of the accident and seismic uncertainties.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 PageA7 Instruments classified as Safety-Related, Seismic Category I, necessary for pressure boundary integrity only, need only consider applicable accident uncertainties. Instruments classified as Non-Safety-Related, Seismic Category I, necessary for safe shutdown, need only consider seismic uncertainties. Instruments classified as Non-Safety-Related, Seismic Category I, necessary for pressure boundary integrity only, need not consider any accident or seismic uncertainties. Instruments classified as Non-Safety-Related, Non-Seismic, need not consider any accident or seismic uncertainties. Note: An instrument is classified as Seismic category I for two reasons; 1) the instrument must either operate during and after a Design Basis Earthquake, or 2) maintain only pressure boundary integrity during a seismic event. The instruments classified as necessary for Safe-Shutdown are designated in FSAR Section 7.4. Additional guidance regarding safety-related and seismic requirements are contained in the original purchasing specifications for the instruments of interest.

14)

Safety Related and Quality Related Engineering calibration calculations will be prepared in accordance with this methodology and will address the following: A) For safety related and quality related instrument loops, Engineering will be responsible for the development and designation of the calibration point values and setpoints listed in the instrument calibration sheet. The data shall include the percent of span value as well as the correlating variable value. This information will be provided in the setpoint calculation prepared for the loop and will be reflected verbatim in the calibration sheet as described in the calculation. B) l&C Maintenance System Supervisors and l&C procedure writers will be accountable for transferring the calibration data from the Engineering calculation into the procedure and for the preparation of the balance of the calibration sheet. Adjustments to the calibration point "percent of span" or "variable" values must be approved by Engineering. In addition, these changes or adjustments must be rolled back into the calculation to ensure consistency between the calculation and calibration data sheet.

1.0 2.0 Scope/Purpose Instrument Setpoint Methodology Appendix A AS-FOUND/AS-LEFT GUIDELINES IC-3.17 Rev. 8 PageA8 The scope of this section of Appendix A is to describe, for St. Lucie Plant, the methodology and guidelines for 1.1 Determining as-found and as-left calibration data uncertainties, and 1.2 Determining allowable value (AV) and as-found tolerance criteria (AFT) for both individual instruments and loops. The purpose of this section of Appendix A is to determine values that can be used during calibration to verify instrument/loop performance with respect to device specifications, performance history, and process requirements. Definitions The following definitions provide clarification to or are in addition to the definitions in Section II of the Standard. 2.1 Allowable Value (AV) The allowable value is a limiting value, without margin, which ensures that the loop was not operating beyond Technical Specification (TS) limits, or for non-TS instruments, the analytical limits. The setpoint allowable value is not applicable to individual instruments in multi-instrument loops. 2.2 Analytical Limit (AL) The analytical limit is the value determined to limit the process. The analytical limit is applied to the output of a given loop. If the safety analysis provides explicit allowances for instrument uncertainty, the setpoint magnitude may be the same as the Technical Specification value. If the safety analysis does not include an explicit instrument uncertainty allowance or the method of applying instrument uncertainty is not known for a particular case, the magnitude of the field setpoint should be conservative to the Technical Specification value. For those cases where the uncertainty is not included in the calculation of the Technical Specification value or where additional conservatism is desired, the Technical Specification value could be used as the analytical limit.

2.3 2.4 Instrument Setpoint Methodology Appendix A AS-FOUND/AS-LEFT GUIDELINES Loop As-Found Tolerance (AFT\QQ/l) IC-3.17 Rev. 8 PageA9 The loop as-found tolerance is the criteria applied to the loop as-found data during calibration to ensure that the loop was operating within the TS limits, or for non-TS instruments, operating within the analytical limits. This acceptance criteria does not include margin but may as long as it is justified in the calculation. The 24 Month Fuel Cycle project (See Reference 7) has determined AFT values that are applicable to both loops (AFTtaap) and individual instruments that are dependent on the calibration procedure and the historical calibration data that has been analyzed. The AFT values from the References are designated AFT95195to indicate that they are based on ADRANo and are expected to include 95/95% of the as-found values measured during calibration. See additional explanation in paragraph 3.3. Device/Instrument As-found Tolerance (AFT in.strJ The device or instrument as-found tolerance is the criteria applied to the as-found data for each instrument during calibration to ensure that the device was operating within its specifications. This acceptance criteria usually does not include margin but may as long as it is justified in the calculation. This acceptance criteria is typically specified as a plus-minus value which can be applied to every point in the calibration. See the description above that addresses AFT95195 values. The AFTinstr can also be found in the Reference 7 in cases where individual instrument calibration data was statistically analyzed. The AFT for either a loop or individual instrument will be provided by the Reference 7. However, there will be cases where those values are not available from the References and will have to be calculated from error values present during and between calibrations. The equation for the AFT for an individual device is: (Equation Vlll-13) AFTinstr = (A2+ D2 + M2 + RES2 + ST2) 112 The AFT Loop is the SRSS of the instruments that are calibrated together. The equation for the AFT of a loop is the SRSS of the Equation Vlll-13 of the individual devices in the loop. The AFT is NOT included in the in the calculation of the DU orTLU

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page A10 but is a value that should be calculated or taken from the Reference with results documented in the calculation results. 2.5 As-found data 2.6 2.7 The as-found data is that data which is collected during calibration before any adjustments are made. As-left data The as-left data is that data which is collected during calibration after all adjustments are made and the instrument is ready to be returned to service. Statistically Determined Drift-AD' The ADRANo 95/95 term denotes the statistically analyzed drift value at 95% confidence and 95% probability. See Reference 3 forthe methodology for statistically determining drift error. The statistically determined drift error represents the statistical average and distribution of the actual calibration as-found verses as-left data for the specific instruments and instrument loops reported in Reference 7. As previously discussed, the error and uncertainty content in As-Found/As-Left (AFAL) calibration data is broader than traditionally defined drift. Each of the following sources of error can contribute to the magnitude of the AFAL drift value:

1. True drift representing a change, time-dependent or otherwise, in instrument/loop output over the period between any two consecutive calibrations.

2. Accuracy errors presented between any two consecutive calibrations.

3. Measurement and test equipment error between any two consecutive calibrations.

There are several additional error contributors to AFAL data variation, but they are usually not significant. The statistical methodology allows for identification of the errors attributable to calibration or procedural process errors. Due to the several independent parameters contributing to the possible variance in calibration data, these independent parameters are all considered together and are termed Analyzed Drift (ADRANo) uncertainty. The AFAL drift value can be used in place of more than just the drift term in the channel uncertainty calculation. For example, it is reasonable to replace calibration M&TE accuracy and readability, device reference accuracy and drift by using the ADRANo error in the calculation of TLU. It would be conservative, but is not necessary, to continue to include those error terms when using the ADRANo error value. The definition of accuracy was previously given as "a number or quantity that defines a limit that errors will not exceed when a device is used under specified operating conditions. It includes all sources of errors not due to environmental variations such as Hysteresis, Repeatability, Linearity, and Deadband." In the discussion of using the ADRANo error term it was mentioned that ADRANo includes accuracy effects but there is

3.0 2.8 Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page A11 an exception. When a function or loop being analyzed is dependent on the dead band accuracy of a device, the DB accuracy must also be included in the calculation of DU or TLU in addition to the ADRANo value. This true because the AFAL calibration data that was analyzed and reported in Reference 7 did not include the reset data for alarm devices, so the device DB behavior was not captured in the analysis results. SettingTolerance (SI) The as-left setting tolerance is the amount by which the as-left value is allowed to deviate from the desired calibration value during calibration. See Section VI of this Standard for a complete discussion of setting tolerance. The ST is usually taken as the device accuracy. 2.9 As-Left Tolerance (ALT) When available, ALT9s1es values for both loops and individual devices should be sourced from Reference 7. These values are expected to encompass 95/95% of the as-left values measured during calibration. The ALT values include the accuracy of the calibrated device and the accuracy and resolution of the M&TE used for device calibration. 2.10 M&IE This term includes the M&TE accuracy and resolution of the M&TE devices used for calibration. The ALT9s19sfrom the Drift Analysis Reports is applied or can be calculated for the ALT value in the uncertainty calculation. This M&TE uncertainty is applied for conservatism in addition to the ALT value but can be neglected when using the ALT value. Methodology 3.1 Uncertainty Combination

3. 1. 1 The methodology employed for calculating the uncertainties is based on the Square-Root-Sum-of-the-Squares (SRSS}

methodology outlined in Section Vofthis Standard.

3. 1.2 Throughout this guideline reference is made to setpoints. These references apply equally to bistable instrument setpoints as well as indication setpoints that require operator action, unless stated otherwise.

3.1.3 Throughout this guideline reference is made to setpoints as if they were high setpoints, with the allowable value and TS/analytical limit greater than the setpoint. These references apply equally to both high and low setpoints with the appropriate change in sign for low setpoints.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page A12 3.1.4 The calculation preparer has the responsibility for utilizing the proper uncertainties for the value being calculated. The uncertainties identified with each equation are representative of the applicable uncertainties to be used. The preparer needs to include or exclude additional uncertainties as appropriate, including those specified by the vendor for the equipment under consideration. Assumptions for inclusion or exclusion should be documented in the calculation. 3.1.5 Bias and dependent terms are not discussed in this section. Treatment of any uncertainty that is a bias or dependent uncertainty shall be in accordance with the methodology description in Section V. 3.2 Uncertainty Equations 3.2.1 The Uncertainty Equations when using the ADRANo and ALT terms vary from those presented in Section VIII. The DU equation from Section VIII is as follows: (Equation Vlll-1) +/-DU= +/-(A2 + D2 + TE 2 + RE2 + S2 + HU 2 + RES2 + ST2 + SPE 2 + PS2+ M2)112 +/- B where: A, D, TE, RE, S, HU, RES, ST, SPE, PS, M, & Bare as defined in Section VI. The equation for DU when using the ADRANo and ALT terms is: (Equation A-1) An effect of the Drift Studies performed per Reference 3 is that the Analyzed Drift (AD) value includes several sources of uncertainty, including the A and M error contributors. The Reference 3 analysis technique does not separate these factors that combine into the AD. The data reported in Reference 7 did not include the DB (reset) accuracy of alarm devices so the DB error remains in Equation A-1. If ADRANo + ADs;as > D then: the results of the drift study AD terms must be used in calculation of DU and replace the A, M, RES and D terms. ALT should also be used in the calculation of DU. If ADRANo+ ADs1As< D then: the vendor drift (D) can be used in the calculation of the DU or TLU if it exceeds the AD. (This becomes equivalent to Equation Vlll-1 ). If it is desired to remove conservatism from the calculation of DU/TLU, the AD and ALT values can be used even when AD< D. Another observation can be made that the ALT term includes the A, M, and RES error values so including this term with its contributing errors is

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page A13 conservative. Therefore, when ALT is included, there is no need to also include the A, M, ST and RES error terms in the calculation of DU or TLU. 3.2.2 Total Loop Uncertainty (TLU) Equation In Section VIII, the Total Loop Uncertainty is defined by SRSS combination of all the appropriate uncertainties as follows: (Equation Vlll-4) +/-TLU = +/- (PC2 + PU2 +DU/+ DU/+... + DUn 2) 112 +/- B where: PC = Process Allowance PU = Primary Element Uncertainties DUn = n number of Device Uncertainties B = Appropriate Biases 3.3 Allowable value (AV) The allowable value can be determined in two different ways (see Section 7 of Reference 4). The two methods are described below. In these two methods uncertainties are divided into two groups: those that are present and measurable (lil<e accuracy or drift) during calibration and those that are not measurable or present during calibration (lil<e accident or process effects). 3.3.1 Method 1 for Determining Allowable value This method starts with the TS or analytical limit and subtracts those uncertainties not present during calibration to arrive at an allowable value. The basis for this method is that the allowable value plus all the uncertainties not present during the calibration checl<will not exceed the analytical limit. The illustration below shows the relationship of the allowable value to a high TS or analytical limit. The Technical Specifications typically address normal operation. The allowable value equation, for a TS limit that is not associated with accident uncertainties is: (Equation A-2) AVn = AL- (HU2 + PC2 + S2 + SPE2 + PS2 + Tn2) 112 This method uses the uncertainties which would not be present during the as-found portion of the calibration. During a calibration checl<, the process considerations (PC} are not present because the process is isolated during a calibration, humidity (HU) uncertainties are not present because their effects are due to conditions not present or the difference between the calibration and operating humidity, and static pressure effect (SPE) is not present during calibration because the calibration is performed at ambient pressure conditions, not at an elevated pressure. The normal temperature effect is not present because the temperature at calibration is seldom near the extremes of the normal temperature variations. The same is true for the power supply

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page A14 effect, its extremes would not be present during calibration. Seismic (S) is considered for RPS and ESFAS plus any function applicable either during or after a seismic event. -r TS/Analytical limit -L Allowable Value

---

Setpoint or Operating Point For an accident associated analytical limit, during the calibration check, in addition to the other effects mentioned, the accident temperature uncertainty (Ta) is not present because it is the effect due to the difference between the calibration and accident operating temperatures, and the insulation resistance effect (IR), seismic effect (S), accident radiation effect (Ra), and chemical spray effect (CSE) are not present because accidents are not part of routine, periodic calibrations. The effects that are not present are included in the calculation of the accident AV. The allowable value equation, for an accident-related analytical limit, is:

(Equation A-3) 3.3.2 Method 2 tor Determining Allowable Value This method starts with the setpoint and adds the uncertainties which are present during calibration and any available margin to arrive at an allowable value. This method establishes a lower limit for the AV based on all the measurable uncertainties during calibration. The illustration below shows the relationship of the allowable value to a high TS or AL for Method 2.

---

TS/Analytical limit I

Allowable Value Nominal Setpoint This method uses the uncertainties which would be present during the as-found portion of the calibration. That is, all the uncertainties not included in Method 1 above, including any available margin, are to be added (for a high setpoint) to the setpoint (SP) to arrive at an allowable value. Indicator resolution is included only if the indicator is relied upon during the calibration process. Accident uncertainties are not included because accidents are not considered to have occurred during a periodic calibration. The allowable value equation is:

3.4 Instrument Setpoint Methodology Appendix A (Equation A-4) AV= SP +((ADRANo)2 + ALT2t' + Margin IC-3.17 Rev. 8 Page A15 where: Margin ~ available margin between the setpoint and the TS/analytical limit. ADRANo and As-left tolerance (ALT) uncertainties are included in this equation because these uncertainties are present due to the past and current calibration. The accuracy and M&TE errors are included in the ADRANo and ALT terms. All elements of accuracy except for dead band (DB) are already included unless the setpoint is a reset action. The temperature (Tc}, and humidity (He) uncertainties for the range of temperatures and humidity present during the calibrations are not included because calibrations are typically performed under environmental conditions that do not vary significantly between calibrations. Since the typical instrument only has significant uncertainty effects for large temperature and humidity variations, the small variations in environmental conditions from calibration to calibration result in insignificant uncertainty effects that can be ignored. The same can be said of the normal radiation effects since that effect does not vary greatly between calibrations. 3.3.3 Application of the two methodologies Calculating the allowable value by each of the two methods above will most likely result in different values. This is expected since each method incorporates complementary portions of the total loop uncertainty values which are normally combined by the square-root-sum-of-the-squares. Depending on the loop specifics, e.g. uncertainty values and margin, one method will yield a value closer to the TS/analytical limit. For those cases with a relatively large amount of margin, Method 1 will typically result in the AV closest to the TS/analytical limit provided the Method 2 value does not use the full margin available. Both Method 1 and Method 2 should be used to calculate an acceptable AV. It is desired that the selected AV meet the requirements of both methods which may result in an AV that contains small, if any, margin. The inclusion of any margin in the Method 2 value needs to be justified in the calculation. There is the possibility that an AV between the two calculated values may be used or that an existing plant incorporated AV lies between the two values and can continue to be used. Loop As-Found (AFT1=) Tolerance The 24 Month Fuel Cycle project (See Reference 7) has determined AFT values that are applicable to both loops and individual instruments that are dependent on the calibration procedure and the historical calibration data that has been analyzed. The methodology for these analyses is found in the Engineering Design Standard STD-IC-3.19 Rev 0, "Design Standard for Analysis of Instrument Drift Data" (Reference 3). "The focus of this standard is to provide methods for statistical analysis of instrument

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page A16 calibration data to statistically determine drift behavior of instrumentation over time with high confidence and probability (i.e., so that during periodic testing instrumentation does not exceed their acceptable limits for a calibration interval, except only on rare occasions)." The results of the analysis of historical calibration data include an Analyzed Drift random uncertainty value, an As-Left Tolerance value (ALT) and an As-Found Tolerance value (AFT). These results are provided in Reference 7. The results are provided for calibration data sets of similar or the same manufacturer model number components or groups of components that were calibrated together. The statistical analysis results apply to the analyzed components/loops and are used in the calculation of instrument uncertainty. The AFTta p values do not include any margin but are used in all cases when the AFTta p value is available from the reports. The AFTtaap values may be conservatively rounded during calibration to account for the readability (RES) of the calibration M&TE. The loop AFT values are used as indicators of loop performance in accordance with vendor specifications and/or the reported analyzed drift values. For instruments or loops composed of devices that are NOT included in Reference 7, the as-found acceptance criteria for the loop output is equal to the allowable value minus any margin desired. The AFTtaap equation is: (Equation A-5) AFTtaop = AV-Margin The following illustration shows the relationship of the AFTta p to the allowable value and the setpoint for such loops.

---

TS/Analytical limit

---

,1~-- Allowable Value

--- Margin (if any) __._ __ AFT(loop)

---

Setpoint or Operating Point It is not necessary for the AFTta p to equal the allowable value. However, the allowable value should be treated as a maximum value for the AFTta p* It should be noted that all AV uncertainties are based on 2a values, i.e. the uncertainty values are equal to the two-sided, 95% probability point for a normal distribution. For setpoints based on 2a values with no margin, there is a 5% probability that during normal operation the loop will fall outside the 2a values used as limits. This is inherent in the method used to calculate setpoints.

3.5 Instrument Setpoint Methodology Appendix A Instrument As-Found Tolerance Criteria (AFT infilrJ IC-3.17 Rev. 8 PageA17 The individual instrument AFT values can be used as indicators of instrument performance in accordance with vendor specifications and the reported analyzed drift values. The purpose of the instrument AFT is to determine if an instrument is operating within specifications. Instrument performance is represented by the AFT values resulting from the statistical analysis of instrument calibration data and/or normal uncertainties which would be present or measured during calibration. Instrument AFT values are provided in Reference 7 for those manufacturer model number instruments included in the 24-month drift project. For those manufacturer model number instruments not included in the drift analysis project, a method similar to that described for Method 2 of calculating allowable values should be used for determining the instrument AFT. Method 2 is based on 2a uncertainties (95% probability) to approximate expected values for normal instrument behavior. Calibration values that exceed the AFTinst, would most likely be indicative of abnormal instrument performance. Additionally, margin can be added to the acceptance criteria based on engineering judgement or specific equipment performance concerns. For those instruments not included in the Reference 7, the typical instrument AFT equation for a single instrument includes the SRSS of uncertainties present during the calibration. (Equation A-6) AFTinst, = +/- {(A2 + D2 + M2 + PS2 + ST2 + RES2) 1/2+Margin} It should be noted that all uncertainties are based on 2a values, i.e. the uncertainty values are equal to the two-sided, 95% probability point for a normal distribution. The equation for the AFT of a loop is the SRSS of the Equation Vlll-13 of the individual devices in the loop. The AFT is NOT included in the in the calculation of the DU orTLU but is a value that should be calculated or taken from the Reference with results documented in the calculation results. 3.6 As-Left Tolerance Instrument (ALT irnilrJ For the instruments included in the Reference 7 there have been As-Left Tolerance values calculated. These values are designated As-Left Tolerance (ALTss1ss), The ALTss1ss provided in the References include calibrated device accuracy, M&TE accuracy used during calibration and the resolution of the M&TE. These single values shall be used in uncertainty calculations to replace the Setting Tolerance (ST) value of the calibration uncertainty. The ALT values are found in the Report and data set in which the calibration data for the instrument or loop was analyzed.

Instrument Setpoint Methodology Appendix A AS-FOUND/AS-LEFT GUIDELINES IC-3.17 Rev. 8 Page A18 The following table provides a quick reference to the terms defined in the standard and their use relative to Appendix A. This table is provided only as a guide and the text should be referred to for detailed use. Term Acron. AV Method AVa AFT9s19s ALT ADRAND 1 2 1 Reference Accuracy A X X X Tech Spec or AL X X Analytical Limit Chemical Spray CSE X Effect Drift D X X ADRAND x1 ALT x2 Deadband DB X Hysteresis H X X Humidity Effects HU X X Insulation IR X Resistance Linearity L X X M&TE M X X X Process Uncertainty PC/PU X X Power Supply Effect PS X X Repeatability REP X X Radiation Effect Ra X Accident Radiation Effect Rn X Normal Readability RES X X X Seismic Effect s X X Nominal Setpoint SP X Static Pressure Eff. SPE X X Setting Tolerance ST X X Temperature Effect Ta X Accident Temperature Effect Tn X Normal Source from X X X Reference 7 Standard Deviation sigma 2 2 2 95/95% 2 95/95% Note 1: Only applicable when ADRANo is available from Reports to replace other errors. Note 2: Only applicable when ALT is available and used to replace included errors.

Instrument Setpoint Methodology Appendix A AS-FOUND/AS-LEFT GUIDELINES EXAMPLE 1 IC-3.17 Rev. 8 Page A19 The following example illustrates the case where the setpoint is much higher than the Technical Specification limit. This case is an example of the ideal case. This example is offered only for illustrative purposes and is not a complete calculation; this example is not a valid representation of the identified equipment. Only enough information is provided to illustrate the application of the methodology, e.g. references and sources are not documented. It is not intended for this example to provide a precedent for preparing calculations. 1.0 PURPOSE/SCOPE 1.1 The purpose of this calculation is to: a) Determine the uncertainties for the turbine trip setpointforthe Reactor Protection System (RPS) and evaluate the existing setpoints considering the determined uncertainties. b) Establish the setting tolerance for the instrument loop. c) Calculate the Allowable Value (AV) for the instrument loop. d) Calculate the As-Found Tolerance (AFT) for the instrument loop for both the instrument and the Technical Specification limits. 1.2 The scope of this calculation is limited to the determination of the above values associated with the following instruments: UNIT TAG MODEL 1 PS-22-101 UE J402-612 1 PS-22-102 UE J402-612 1 PS-22-103 UE J402-612 1 PS-22-104 UE J402-612 2 PS-22-95A UE J302-612 2 PS-22-95B UE J302-612 2 PS-22-95C UE J302-612 2 PS-22-95D UE J302-612

Instrument Setpoint Methodology Appendix A 1.3 Loop Description IC-3.17 Rev. 8 PageA20 Each of these loops consist of a single instrument: a pressure switch measuring the pressure of the electro-hydraulic fluid used to control the turbine. There is one switch for each measurement channel.

2.0 REFERENCES

2.1 (Listed as appropriate... ) 3.0 METHODOLOGY 3.1 The setpoint function provides a loss of turbine signal to the RPS. This signal is only meaningful during normal operation; therefore, only the normal loop uncertainties will be determined. 3.2 Since the setpoint is not required for reactor protection or safe-shutdown of the plant (Bases 4.1.2), a graded approach will be utilized for determining loop uncertainties. The graded approach involves using only the applicable uncertainties specified by the vendor (e.g. accuracy) or others deemed appropriate (e.g. drift). For uncertainties which were not specified by the vendor, if the instrument is operated within specified parameters, unspecified uncertainties associated with those parameters (e.g. power supply, temperature, humidity) are assumed to be either negligible or included in accuracy. 3.3 The acceptability of the setpoint will be determined by calculating the normal loop uncertainty, applying it to the established setpoint, and verifying that the bases identified in Section 4 have been met. 3.4 The methodology employed by this calculation for the application of uncertainties is in accordance with the Instrument Setpoint Methodology. 4.0 ASSUMPTIONS/BASES 4.1 Bases 4.1.1 PSL Unit 1 and 2 Technical Specifications (TS) identify the trip setpoint (;:;:800 psig) and the allowable value (;;:BOO psig) for the loss of turbine signal. 4.1.2 The bases of the setpoint is to provide turbine protection, reduce the severity of the loss of turbine transient, and help avoid the lifting of the

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page A21 main steam line safety valves during the transient. No credit for this setpoint is taken in the accident analyses. The setpoint is required to enhance the overall reliability of the RPS. This setpoint is not required for reactor protection. 4.1.3 The loops have the following specifications: 4.2 Assumptions Adjustable Range= 200 to 3000 psig Adjustable Span= 2800 psi Setpoint = 1000 psig decreasing 4.2.1 These pressure switches were not included in the analysis of calibration data to determine instrument drift and the Report of Reference 7 do not apply. Drift is not specified by the vendor, so is assumed to be equal to device repeatability. 4.2.2 The temperature for instruments in the Turbine Building (TB} is assumed to be the same as the outdoor temperature since the TB is open and exposed to the outside atmosphere. The calibration temperature is 68°Fwith the maximum normal temperature being93°F. The differential is +25°F. The radiation in the TB is also negligible.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page A22 5.0 CALCULATION 5.1 NLU, AV and AFT Determination NOTES: The following table itemizes all the applicable uncertainties for each instrument. These uncertainties are considered random, independent errors unless otherwise stated. Unit 1 PS-22-101/102/103/104 Unit 2 PS-22-95A/B/C/D Uncertainty Value(% adjustable range) Source /Note A N/A 1 D +/- 1.5% Assumption 4.2.1 M +/- 1.5% 2 PC N/A 3 Rn N/A Assumption 4.2.2 REP +/- 1.5% 1 ST +/- 1.5% 4 Tn +/-0.5% 5 NLU +/-3.04% 6 +/- 85 psi AVM1 814 psig 7 AVM2 916 psig 7 AFTinstr +/- 3.0% +/- 84 psi 8

1.

The vendor specifies repeatability, instead of accuracy.

2.

M&TE is required to have accuracies equal to or better than the equipment setting tolerance. For conservatism, the setting tolerance of the calibrated instrument will be used for all M&TE used to calibrate that instrument. The switch requires only one calibrated M&TE for the input.

3.

There are no process considerations which affect these loops. There is no significant static head which needs to be considered.

4.

Setting tolerance is equal to repeatability for the switch.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 PageA23

5.

The temperature uncertainty specified is interpreted to be linear over its specified range and is combined with the temperature rise identified in Assumption 4.2.2. Tn = +/- 1 o/o of adjustable span per 50°F change* 25°F change

6.

The NLU was calculated by the following equation in accordance with the methodology of Section 3.0. NLU = +/- (02 + M2 + REP2 +SF+ Tn2) 112

7.

The AV was calculated by the following equation in accordance with the methodology. (Note: Margin is assumed to be zero for this calculation.) AVM1 =TS+ [(Tn2) 112 (SPAN)+ Margin] AVM1 = 800 + 14 = 814 psig AVM2 = SP- [ (02 + M2 + REP2 + SF) 112 (SPAN)+ Margin] AVM2 = 1000- 84 = 916 psig The preferred value to use is AVM1; therefore, AV= AVM1 = 814 psig

8.

The AFTinstr was calculated by the following equation in accordance with the methodology of Section VIII (Equation Vlll-13). AFTinstr = (02 + M2 + REP2 + SF) 112 5.2 Setpoint Evaluation The setpoints will be evaluated by applying the loop uncertainty data and determining if the bases identified in Section 4 are being met. Considering the normal loop uncertainty, the setpoint is 1000 +/- 85 psig. This setpoint with uncertainty has 115 psi of margin before reaching the TS limit of

,

800 psig.

Unit 1 PS-22-120 has a low alarm at 1550 psig for the electro-hydraulic (EH) fluid. This establishes the minimum system pressure and the upper limit for the RPS setpoint in order to avoid spurious RPS actuation. As can be seen from the diagram below, there is a substantial difference between the minimum pressure and the RPS setpoint. Unit 2 does not have a pressure switch corresponding to PS-22-120; however, based on the similarity of the systems, EH pressures are approximately the same for both units.

6.0 RESULTS Psig Instrument Setpoint Methodology Appendix A Description 1550 ~----~Lo EH Pressure 1085 -----+ NLU/AFT= +1084 psig 1000------* Setpoint 915 ----'----- - NLU/(~AFT= 916 psig) 814 ------AVM1 800 -----TS Limit & TS AV IC-3.17 Rev. 8 Page A24 6.1 The following table shows the setpoints and the calculated values. The setpoints with their associated normal loop uncertainty have been found acceptable for their application. Note that all values specified in% are percent of span. Unit Tag SP ST NLU AVM1 AFT inst 1 PS-22-101 1000 psig +/- 1.5% +/-3.04% +/-3.0% PS-22-102 Deer +/- 42 psig +/- 85 psig 814 psig +/- 84 psig PS-22-103 PS-22-104 2 PS-22-95A 1000 psig +/- 1.5% +/-3.04% +/-3.0% PS-22-95B Deer +/- 42 psig +/- 85 psig 814 psig +/- 84 psig PS-22-95C PS-22-95D

Instrument Setpoint Methodology Appendix A AS-FOUND/AS-LEFT GUIDELINES EXAMPLE2 IC-3.17 Rev. 8 PageA25 This example is offered only for illustrative purposes and is not a complete calculation; this example is not a valid representation of the identified equipment. Only enough information is provided to illustrate the application of the methodology, e.g. references and sources are not documented. It is not intended for this example to provide a precedent for preparing calculations. 1.0 PURPOSE/SCOPE The purpose of this calculation is to determine the Normal Loop Uncertainties (NLU) for the narrow range Pressurizer Pressure instrumentation (P-1103 & 4) alarms/interlock setpoints for the Shutdown Cooling System (SOCS) suction and Safety Injection Tank (SIT) discharge valves, and the low temperature overpressure protection (LTOP) setpoints for the power operated relief valves (PO RVs). Unit Tag 1 PT-1103-PY-1103-PA-1103(PORV) 1 PT-1104-PY-1104-PA-1104 (PORV) 1 PT -1103-PIC-1103 (SIT/SOC) 1 PT-1104-PIC-1104 (SIT/SOC)

2.0 REFERENCES

2.1 FRAM-00012-REPT-005 Rev 0 "St. Lucie Nuclear Power Plant Units 1 & 2, 24-Month Fuel Cycle Project, Drift Analysis Summary Report" 3.0 METHODOLOGY The methodology employed by this calculation for the application of uncertainties is in accordance with the Instrument Setpoint Methodology. 4.0 ASSUMPTIONS/BASES 4.1 Rosemount transmitter drift was analyzed to support the 24-month fuel cycle project. The results of the statistical analysis of calibration data are presented in Reference 2.1. These results will be applied to the transmitter manufacturer model number and application addressed by this calculation.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 Page A26 4.2 The statistical analysis of the historical calibration data was also performed for the other modules/devices addressed by this calculation. The historical drift values for these modules are presented in Reference 2.1 and will also be included in this calculation. 5.0 CALCULATION 5.1 Environmental Parameters The pressurizer pressure transmitters are located within the Reactor Containment Building (RCB). The remaining modules are located within the RTGB cabinets in the control room. The environmental conditions for these areas are outlined in Table 5-

1.

Table 5-1 Environmental Control Room RCB Parameter (normal) Temperature (°F) 80°F Max. normal 120°F Radiation (RADs) Negligible 1.5E5 Rad/60yr. (Normal) Pressure ~atmospheric atmospheric Calibration Temp. (°F) 68°F 65°F 5.2 Uncertainty Determination The individual uncertainty terms are summarized in Table 5-2 for each device in the typical pressure loop. The precision resistor is in series and does not affect the loop current signal. Refer to the applicable note for the determination of individual device uncertainty parameters. The uncertainty terms were combined as random independent terms using the Section 3.0 methodology to determine the total device uncertainty and NLU.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 PageA27 P-1103 Instrument Loop Device Uncertainty Effects and Total Loop Uncertainty (also typical for P-1104) Table 5-2 DEVICE UNCERTAINTY Element of Uncertainty (values are+/- unless denoted otherwise) PT<1i py(2) PA<3l PIC<4l A NIA NIA NONE NIA L NIA NIA NIA NIA ALTss,ss 0.31 0.199 1.031 M NIA NIA NIA ADRAND 0.261 0.273 0.957 PC NIA NIA NIA NIA PS NIA 0.15 0.15 NIA Rn NIA NIA NIA NIA SPE NIA NIA NIA NIA Tn 0.43 0.12 0.12 0.36 DB NIA NIA NIA 1.00 REP NIA NIA NIA NIA e Uncertainty +/-0.59 +/-0.43*** +/-1.76 NLU SOC &SIT +/-1.86% (29.7 psi)* NLU LTOP +/-0.73% (11.7 psi)**

• The NLU values were determined utilizing Section 3.0 Methodology as follows

[(0.59)2pr + (1.76)2p1c]1' 2* It should be noted that the 'PY' module is part of the current loop; however, it does not contribute to uncertainty for the 'PIC' module.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 PageA28

• • The NLU values were determined utilizing Section 3.0 Methodology as follows

[(0.59)2pr + (0.43)2 PY/PA ]112

• • • The combined uncertainty of the PY and PA devices (+/-0.43%) is the SRSS of all the errors for the two devices taken once.

NOTES: (1) Transmitter data taken from vendor data, unless specified otherwise. ALT - From Reference 2.1 the transmitter As-Left Tolerance including M&TE is +/-0.31 % for the Rosemount 3154 transmitters 1-PT-1103 and 1-PT-1104. This information is found in the reference within the results for the XTR-04 data set. AD - From Reference 2.1 the transmitter analyzed drift is +/-0.261 % with zero analyzed bias as presented in the XTR-04 data set. This is a 30 month value and is slightly larger than the vendor specified drift value that would have been calculated from the vendor specification. Tn - Temperature effect is specified as +/-(0.15% URL +0.60/ospan)/100°Fforthe average normal/shutdown relative to calibration LlTemperatures from Table 5-1 can be determined as follows: Tn = +/-{0.15(2014.7)/(1600) + 0.6}(120-65)/100 = +/- 0.43% Span Device Uncertainty= (0.31 2 + 0.261 2 + 0.432) 112 = +/- 0.59% CS (2) Isolated Signal Transmitter & Alarm Unit (PY-1103/PA-1103 or PY-1103/PA-1103-1) data taken from vendor data unless specified otherwise. ALT-In the Procedure 1-SMl-01.37L the devices PY-1103/PA-1103 or PY-1103/PA-1103-1 are calibrated together. The setting tolerance for this combination combined with the accuracy of the M&TE used to calibrate the combinations is provided in Reference 2.1 for the data set ALML-02. The As-Left Tolerance (ALT) value from Reference 2.1 is +/-0.199% span. ALT= +/-0.1990/oSpan M - The M&TE for calibration is included in the ALT therefore the M term does not have to be repeated. AD - From the ALML-02 data set of Reference 2.1 the drift based on statistical analysis of historical calibration data is +/-0.273% span with no bias for the combination of PY-1103/PA-1103 or PY-1103/PA-1103-1.

Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 PageA29 Tn - For PA-1103 or PA-1103-1: Uncertainty of +/-0.5% of span maximum for a 50°F change in ambient temperature, so that a proportional response for a 12°F change would equal: Tn = 0.5(12/50) = +/- 0.12% span. Devices (PY/PA) Uncertainty= (0.1992 + 0.2732 + 2(0.15)2 + 2(0.12)2) 112= +/-0.43% CS (3) Pressure indicating controller (PIC-1103/4) based on a Sigma model 9266 and data taken from vendor information unless specifically stated otherwise. ALT - In the Procedure 1-SMl-01.37L the device PIC-1103 alarms are calibrated. The setting tolerance for the alarms combined with the accuracy of the M&TE used to calibrate them are provided in Reference 2.2 in the data set ALM-04. The As-Left Tolerance (ALT) value from reference 2.2 includes setting tolerance, M&TE and readability and has the value +/-1.031 % span. ALT (SW)= +/-1.031 % Span M - The M&TE values and resolution are from the same Reference 2.2 for PIC-1103 and are included in the ALT and do not have to be repeated. AD-From the ALM-04 data set of Reference 2.2 the drift based on statistical analysis of historical calibration data is +/-0.957% span with no bias for the alarms of PIC-1103. T - Temperature effect is stated as 300 ppm/°F or +/-0.03%/°F, such that for a control room fluctuation of 12°F (maximum of 80°F, relative to a calibration temperature of 68°F, reference Table 5-1) the temperature effect can be determined as follows: T = +/-0.03%(12) = +/-0.36% span DB-Vendor stated Dead band is +/-1 % of full scale and must be included because functions are performed in both increasing and decreasing directions. Device (PIC) Uncertainty= (1.031 2 + 0.9572 + 0.362 + 1.002 ) 112= +/-1.76% CS

6.0 RESULTS Instrument Setpoint Methodology Appendix A IC-3.17 Rev. 8 PageA30 The uncertainty and field calibration data for the pressurizer pressure narrow range instrumentation are provided within Table 6-1. The NLU for the SOC interlock/alarm setpoints is intended for use in establishing SOC system relief valve setpoints. The function of the SIT interlocks is two-fold, i.e., to allow manual isolation of the SITs prior to SOC operation, and to ensure auto-open of the SIT discharge valves upon heatup. The bases of the SIT interlock setpoints is dependent on the SOC interlock setpoints. Strict administrative controls ensure proper sequence of operation for the SDC/SIT valves. The existing auto-open/permissive-close setpoint(s) at 350 psig and NLU of +/-29.7 psi are suitable to ensure proper operation relative to the SDC valve interlocks. The LTOP PORVs are designed to preclude any over-pressurization transient from exceeding the pressure-temperature operating limits presented in the Technical Specifications. The uncertainty calculation demonstrates that the NLU for the LTOP pressure interlocks is within the +/-20 psi allowance. Table 6-1 Uncertainty Data NR Pressurizer Pressure Range 0-1600 psia Output Device PIC-1103 PIC-1104 PA-1103, 1103-1 PA-1104, 1104-1 Functional Description SOC/SIT Interlocks/Alarms LTOP Interlocks/Alarms Loop Uncert +/-1.86 %span (+/-29.7 psi) +/-0.73 %span (+/-11.7 psi) NOTES: (1) Uncertainty values based on drift for a maximum calibration period of 30 months (typical refuel calibration period of 24 months+ 25% performance allowance).

Instrument Setpoint Methodology Appendix B TURKEY POINT SETPOINT PROGRAM PLAN AND SPECIFIC GUIDELINES/ASSUMPTIONS IC-3.17 Rev. 8 Page 81 This appendix describes the Turkey Point Setpoint Program and provides guidelines and assumptions specific to the Turkey Point Plant. Instrument uncertainty and setpoint calculations are to be performed in accordance with the instructions contained in the main body of this methodology document. The guidelines and assumptions contained in this appendix are available for use in the preparation of setpoint calculations when needed. These assumptions are considered conservative and are intended to reflect actual plant practices. Use of these assumptions provides both a standardized approach and a means of minimizing redundant error.

Instrument Setpoint Methodology Appendix B TURKEY POINT PROGRAM PLAN IC-3.17 Rev. 8 Page B2 Setpoint Classifications: The Setpoint Classification System developed for use at Turl<ey Point includes five classifications or categories. It is important to note that these setpoint classifications are independent of, and may be different from, the associated devices' safety classification as contained in the Total Equipment Data Base (TEDB). For example, a given device may be classified Safety Related in TEDB because it forms part of the RCS pressure boundary while performing no other safety function. Even though the device itself is designated Safety Related, the setpoint associated with that device is assigned one of the non-Safety Related setpoint classifications. The five categories used at Turl<ey Point and their definitions are: Category 1: BPS/ESFAS Setpoints These are setpoints required by the Turl<ey Point Technical Specifications or FSAR as part of the RPS or ESFAS. Technical Specification 2.2 defines the RPS setpoints and Technical Specification 3.3.1 defines the RPS instrumentation. Technical Specification 3.3.2 defines both the ESFAS instruments and their setpoints. The RPS and the ESFAS are also discussed in Sections 7.2.2 and 7.5 respectively of the Turl<ey Point FSAR. category 2: Functionally Safety Related A setpoint is considered to be Functionally Safety Related if it meets any one or more of the following criteria:

1) The setpoint is essential to emergency reactor shutdown, containment isolation, reactor core cooling, or containment and reactor heat removal, or is otherwise essential in preventing significant release of radioactive material to the environment.

2) The setpoint is part of a process essential to maintain plant parameters within acceptable limits established for a design basis event as defined in the FSAR.

3) The setpoint is essential to a supporting system (such as cooling, lubrication, etc.) which is required for a safety system to accomplish its function.

4) The setpoint is an integral part of a system, process, or supporting system which FPL has made specific commitments to classify and control as Safety Related (e.g., Cold overpressure Mitigation System).

Instrument Setpoint Methodology Appendix B IC-3.17 Rev. 8 Page B3 Category 3: Important to Safety: A setpoint is considered Important to Safety if it meets any one or more of the following criteria:

1)

2)

3)

4)

5)

6)

The setpoint is essential to maintaining the plant within operating limits as defined in the Technical Specifications for normal plant operations. The setpoint is used for Technical Specification surveillance or is relied upon to ensure a Technical Specification condition is met for a component or system. The setpoint is a functional part of a system which can indirectly cause a reactor trip, ESF actuation, or other challenge to plant safety systems. The setpoint is an integral part of a system which may be relied upon as a backup to a Safety Related function. The setpoint is an integral part of safe shutdown capability in the event of an Appendix R fire event. The setpoint is an integral part of a supporting system to a Safety Related system but does not meet the Category 2 (Functionally Safety Related) definition of essential for accomplishment of a safety function. Category 4: Important to Plant Operation or Personnel Safety: A setpoint is considered to be in this category if it meets any one or more of the following criteria: Category 5:

1) The setpoint can directly affect the operation of a system or major piece of equipment which is necessary to operate the plant effectively.

2) The setpoint is an integral part of a system which is relied upon to protect large plant investment equipment.

3) The setpoint is an integral part of a system which may be relied upon as a backup to an Important to Safety function.

4) The setpoint is an integral part of a system which protects against or could cause injury to personnel on malfunction.

Not Important: This category is comprised of all remaining setpoints which do not meet any of the criteria for classification into categories 1 through 4.

SETPOINT DOCUMENTATION: Instrument Setpoint Methodology Appendix B IC-3.17 Rev. 8 Page B4 Turkey Point instrument setpoints are documented in controlled plant drawings 5613-M-313 (Unit 3), 5614-M-313 (Unit 4), and 5610- M-313 (common to both units). Setpoint data is also included in the Total Equipment Data Base {TEDB), which at some time in the future will fully replace the M-313 drawings. Category 1 setpoints are recorded in drawings 5613/14-J-839 and their bases are documented in 5613/14-J-838. New instrument setpoints that require a setpoint calculation and that perform a safety related function or are required for Technical Specification compliance associated with FPL Nuclear Plants shall be developed on the graded approach basis of this standard with the exception of the Reactor Protection System (RPS) and Engineered Safety Features Actuation System (ESFAS) at Turkey Point Units 3 & 4. Those RPS and ES FAS setpoints were established using the Westinghouse methodology described in WCAP-12745 for PTN. For consistency, any new or modified Turkey Point RPS or ESFAS setpoints should follow the methodology described in the WCAP. The Bases for Turkey Point RPS/ESFAS setpoints are contained in WCAP-12201. Both WCAP-12745 and WCAP-12201 were revised to reflect instrument setpoint changes resulting from the Thermal Uprate Project. Revision 1 of WCAP-12745 (methodology document) was issued in December 1995, and Revision 2 of WCAP-12201 (bases document) was issued in February 1996. The Westinghouse methodology contained in WCAP-12745 differs slightly from the FPL methodology in IC-3.17. However, due to the Westinghouse treatment of random errors, the WCAP-12745 methodology is conservative with respect to IC-3.17. NON-STANDARD SETPOINTS:

1.

As noted above, RPS/ESFAS setpoints were established by Westinghouse using their own proprietary methodology. The Westinghouse methodology is described in WCAP-12745. Therefore, formal IC-3.17 formatted calculations do not exist for these setpoints. Due to the conservative nature of the differences between the two methodologies, there is no need to revise existing RPS/ESFAS setpoint documentation for compliance with IC-3.17, and new RPS/ESFAS setpoints calculated using the Westinghouse methodology shall be considered to be acceptably documented.

2.

Setpoints for containment particulate and gaseous radiation monitors, R-11 and R-12, as defined in the Turkey Point Technical Specifications, are maintained and adjusted by the Nuclear Chemistry Department. As such these setpoints are neither calculated nor documented in accordance with IC-3.17.

Instrument Setpoint Methodology Appendix B TURl<EY POINT ASSUMPTIONS AND GUIDELINES IC-3.17 Rev. 8 Page B5

1.

Measuring and test equipment (M&TE) is generally specified in the calibration procedures and its accuracy should be used in calculations whenever possible. If not specified, the M&TE accuracy can be assumed to be equivalent to the Reference Accuracy of the device being calibrated.

2.

If the vendor does not specify drift error, it can be assumed that the drift term is equal to the device Reference Accuracy. Unless otherwise stated, an 18-month calibration cycle (refuel interval) can be assumed.

3.

Barometric pressure effects can be assumed to be calibrated out or insignificant.

4.

If the instrument is located in a mild environment, radiation effects can be assumed to be negligible unless the instrument is required to function following an accident and is located in an area that will be affected by radiation leakage from containment.

5.

Any variations in device mounting are within the tolerance of the vendor installation requirements and any error induced from orientation can be considered negligible unless specifically identified.

6.

Any static head corrections should be verified to be part of the calibration process (maintenance procedures). If not, they must be included in the calculation.

7.

If a vendor represents a device as "seismically qualified", and no quantitative data concerning the seismic effects for the device are included in the vendor documents, it can be assumed that the device performs no worse than Reference Accuracy during a seismic event and the only seismic induced effect would be contact chatter. (Spurious actuation from contact chatter is assumed conservative, e.g., the device actuates, and performs its safety function. Following the seismic event, the device remains functional and can be reset or resets automatically. The pre-seismic event configuration is restored and the device can be returned to service). Hence, seismic effects can be assumed equivalent to the Reference Accuracy of the device. It can be further assumed that the devices will be recalibrated following. a seismic event.

8.

The component cooling water (CCW) and turbine plant cooling water (TPCW) systems contain molybdates for corrosion prevention. It can be assumed the temperature switch bulb heat transfer characteristics are not adversely affected from plating or corrosion and any induced error from diminished heat transfer can be considered negligible.

9.

If the vendor does not specify temperature effect error, it can be assumed to be equal to the device Reference Accuracy.

10.

Normally, calibration tolerance is included in the maintenance procedures. If not, Reference Accuracy should be used as calibration tolerance in the calculation.

~ IC-3.17 Setpoint Methodology Revision 8 Page 1 of 2 Tanner Clink Technical Support Engineer Rosemount Nuclear Emerson A1.1tomation Solutions 8200 Market Blvd Chanhassen, MN 55317 USA T +1 952 949 5200 E RNll.info@Emerson.com August12,2024 To: Emerson/ Rosemount Nuclear Customer

Subject:

3150 Series High Static Line Pressure Specifications The intent of this letter is to provide clarity and guidance on the published static line pressure specification and the manner in which Rosemount Nuclear Instruments, Inc. (RNII) intends for it to be implemented. Over the past 50 years of the 1150 series transmitters and into the 3150 series transmitters, the line pressure specifications have evolved as we've collected additional performance data and received customer feedback. With the launch of the 3150 series in 2010, the line pressure specification was written in a way that both incorporated legacy customer feedback and provided a more clear and conservative specification. For static line pressure zero effect, the factory intent has been for the specification to be a step type function. This is a highly conservative approach which aligns with our standard production tests and product audit test programs used to evaluate and validate static line pressure zero and span, where testing is conducted in 1000 psi increments. As it relates to interpolation of the 3150 zero effect specification, we know the zero effect is not systemic and not fully linear over line pressure. This is especially true for low line pressures below 500 psi, as a linear interpolation (or reduction) of the uncertainty specification can become less conservative. That said, for calculations of error involving line pressure ;?:500 psi, a linear interpolation would remain conservative based on our available data. Therefore, the following are acceptable approaches to addressing static line pressure zero effect: For static line pressure::;; 500 psi, linear interpolation of the static line pressure zero effect specification in 500 psi intervals. For static line pressures > 500 psi & < 1000 psi, linear interpolation of the static line pressure zero effect specification between 500 psi & 1000 psi intervals. For static line pressures;;:: 1000 psi & ::;; the static pressure limit, linear interpolation of the static line pressure zero effect specification in 1000 psi intervals.

IC-3.17 Setpoint Methodology Revision 8 Page 2 of 2 Tanner Clink Technical Support Engineer Rosemount Nuclear Emerson Automation Solutions 8200 Market Blvd Chanhassen, MN 55317 USA r +1952949.s200 E RNll.lnfo@Emerson.com Regarding interpolation of the static line pressure span effect specifications of pressure range codes 1 i 2, and 3, the published specification may be linearly interpolated for line pressures ~500 psi and s; the static pressure limit in the same manner as the zero effect specification. For pressure ranges 4 and 5, correction for the systemic span shift should be performed during calibration as outlined in section 3 of the 3150 Series Reference Manual 00809-0100-4835. Interpolation of the remaining span correction uncertainty is the approved method for all line pressures, as this systemic span effect or shift over line pressure is linear and repeatable for these pressure ranges. P!ease note that Rosemount Nuclear also provides a static line pressure factory calibration service to determine transmitter specific zero and span effects at static line pressure. This would allow the end-user to leverage the actual SLP effects instead of the enveloping uncertainty. This test option can be used to establish the systemic effect for individual units and is available with all 3150 series DP transmitters using our 'P4' standard model option. If you have any further questions, please do not hesitate to reach out to me.at (952)- 949-5200 or RNll.info@Emerson.com. Tanner Clink Technical Support Engineer Rosemount Nuclear Instruments, Inc.

IC-3.17 Setpoint Methodology Revision 8 Page 1 of 2 ~ EMERSON.. November 16, 2018 Rosemount Nuclear Instruments, Inc. 8200 Market Boulevard Chanhassen, MN 55317 USA Tel 1 (952) 949-5210 Fax 1 (952) 949-5201 www.RosemountNuclear.com To: Emerson Automation Solutions I Rosemount Nuclear Customer

Subject:

Rosemount 3150 Series Nuclear Pressure Transmitter Performance Specifications The purpose of this letter is to clarify the statistical basis of product specifications for the 3150 Series family of nuclear qualified pressure transmitters (including models 3152N, 3153N, 3154N and 3155N) as published in applicable Product Data Sheets. The conclusions listed below are based on manufacturing testing and screening, final assembly acceptance testing, periodic (typically quarterly) product audit testing of transmitter samples and limited statistical analysis. Please note that all performance specifications are based on zero-based calibration ranges under reference conditions (ambient temperature and pressure). Additionally, there are no conclusions inferred with respect to confidence levels associated with any specifications. Performa nee Specifications

1. Reference Accuracy All (100%} 3150 Series transmitters are tested to verify accuracy to +/-0.2% of span at 0%, 20%, 40%, 60%,

80%, and 100% of span. Therefore, the published reference accuracy specification is considered to be +/-3cr.

2.

Drift The tolerance interval was determined by enveloping the observed shifts from type tests. Based on the type test sample, the published drift specification is considered to be +/-2a.

3. Ambient Temperature Effect All (100%) 3150 Series transmitters are tested following final assembly to verify compliance with the published temperature effect specification. Therefore, the published ambient temperature effect specification is considered to be +/-3cr.

4. Overpressure Effect Testing of this specification is performed at the sensor module sub-assembly level. All (100%) range 1 through 6 sensor modules are tested for compliance to specifications. Based on the production sub-assembly test and periodic audit test performance, the published overpressure effect specification is considered +/-3cr.

5.

Static Line Pressure Effect Testing of this specification is performed at the sensor module sub-assembly level. All (100%} range 1 through 5 sensor module sub-assemblies are tested for compliance with static pressure zero effect specifications (SLP effect is not applicable for range 6). Periodic product audit testing performed on all differential ranges (1 through 5) has also shown compliance with static pressure zero and span effect specifications. Therefore, the published static pressure effect specification is considered to be +/-3cr. ROSEMOUNT" Nuclear Page 1 of 2

lC-j,l'J :::ietpomt Method.ology KeVISlOil H Page 2 of 2

6. Power Supply Effect Testing for conformance to this specification is performed on all transmitters undergoing periodic

,, c*********prpd~ftaud,i!JeJtiog:~asel:I c,n.cl.~#{tt~stres~lts~t~e;pl.11:>Usn~ct R9We,r;os1JAply,eff~ctsp~cifi~ation.c~n;,;.*******

• be.ci>rYside}*e~+/-3<r_............ *****.......,... *......,

For any additional questions, please contj:lct your Emerson Automc1tion Solutions I Rosemount Nuclear ..,.. ~,~,~rr partner or our technical support team at RNll.info@emerson.com or by phone at 1~952-949~ Brian Kocher I Sr. Principal Application Engineer Emerson Automation Solutions I Rosemount Nuclear 8200 Market Blvd Chanhassen MN 55317 USA Brian.Kocher@Emerson.com ROSEMOUNr Nuclear Page 2 of 2}}