ML993560101

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(Duplicate of ML993560062) Revision 3 to Regulatory Guide 1.105, Setpoints for Safety-Related Instrumentation. (Draft Was DG-1045)
ML993560101
Person / Time
Issue date: 12/31/1999
From:
Office of Nuclear Regulatory Research
To:
References
RG-1.105, Rev. 3
Download: ML993560101 (8)


Text

t,

==

E(.

==

U.S.

==

NUCLEAR

==

REGULATORY

==

COMMISSION

==

Revision

==

3

==

P

==

    1. ,December

==

1999

==

3

==

REGULATORY

==

GUIDE

==

OFFICE

==

OF

==

NUCLEAR

==

REGULATORY

==

RESEARCH

==

REGULATORY

==

GUIDE

==

1.105

==

(Draft

==

was

==

DG-1045)

==

SETPOINTS

==

FOR

==

SAFETY-RELATED

==

INSTRUMENTATION

==

A.

==

INTRODUCTION

==

Criterion

==

13,

==

"Instrumentation

==

and

==

Control,"'

==

of

==

Appendix

==

A,

==

"General

==

Design

==

Criteria

==

for

==

Nuclear

==

Power

==

Plants,"

==

to

==

10

==

CFR

==

Part

==

50,

==

"Domestic

==

Licensing

==

of

==

Production

==

and

==

Utilization

==

Facilities,"

==

requires,

==

among

==

other

==

things,

==

that

==

instrumentation

==

be

==

provided

==

to

==

monitor

==

variables

==

and

==

systems

==

and

==

that

==

controls

==

be

==

provided

==

to

==

maintain

==

these

==

variables

==

and

==

systems

==

within

==

prescribed

==

operating

==

ranges.

==

Criterion

==

20,

==

"Protection

==

System

==

Functions,"

==

of

==

Appendix

==

A

==

to

==

10

==

CFR

==

Part

==

50

==

requires,

==

among

==

other

==

things,

==

that

==

the

==

protection

==

system

==

be

==

designed

==

to

==

initiate

==

operation

==

of

==

appropriate

==

systems

==

to

==

ensure

==

that

==

specified

==

acceptable

==

fuel

==

design

==

limits

==

are

==

not

==

exceeded.

==

Paragraph

==

(c)(1)(ii)(A)

==

of

==

§

==

50.36,

==

"Technical

==

Specifications,"

==

of

==

10

==

CFR

==

Part

==

50

==

requires,

==

in

==

part,

==

that,

==

where

==

a

==

limiting

==

safety

==

system

==

setting

==

is

==

specified

==

for

==

a

==

variable

==

on

==

which

==

a

==

safety

==

limit

==

has

==

been

==

placed,

==

the

==

setting

==

be

==

so

==

chosen

==

that

==

automatic

==

protective

==

action

==

will

==

correct

==

the

==

abnormal

==

situation

==

before

==

a

==

safety

==

limit

==

is

==

exceeded.

==

It

==

also

==

requires,

==

among

==

other

==

things,

==

that

==

the

==

licensee

==

notify

==

the

==

NRC

==

if

==

the

==

licensee

==

determines

==

that

==

an

==

automatic

==

safety

==

system

==

does

==

not

==

function

==

as

==

required.

==

The

==

licensee

==

is

==

required

==

to

==

then

==

review

==

the

==

matter

==

and

==

record

==

the

==

results

==

of

==

the

==

review.

==

1

==

For

==

the

==

full

==

text

==

of

==

the

==

General

==

Design

==

Criteria

==

and

==

other

==

sections

==

of

==

the

==

regulations

==

cited

==

in

==

this

==

guide,

==

see

==

10

==

CFR

==

Part

==

50,

==

"Domestic

==

Licensing

==

of

==

Production

==

and

==

Utilization

==

Facilities."

==

Regulatory

==

guides

==

are

==

issued

==

to

==

describe

==

and

==

make

==

available

==

to

==

the

==

public

==

such

==

information

==

as

==

methods

==

acceptable

==

to

==

the

==

NRC

==

staff

==

for

==

implementing

==

specific

==

parts

==

of

==

the

==

NRC's

==

regulations,

==

techniques

==

used

==

by

==

the

==

staff

==

in

==

evaluating

==

specific

==

problems

==

or

==

postulated

==

accidents,

==

and

==

data

==

needed

==

by

==

the

==

NRC

==

staff

==

in

==

its

==

review

==

of

==

applications

==

for

==

permits

==

and

==

licenses.

==

Regulatory

==

guides

==

are

==

not

==

substitutes

==

for

==

regulations,

==

and

==

compliance

==

with

==

them

==

is

==

not

==

required.

==

Methods

==

and

==

solutions

==

different

==

from

==

those

==

set

==

out

==

in

==

the

==

guides

==

will

==

be

==

acceptable

==

if

==

they

==

provide

==

a

==

basis

==

for

==

the

==

findings

==

requisite

==

to

==

the

==

issuance

==

or

==

continuance

==

of

==

a

==

permit

==

or

==

license

==

by

==

the

==

Commission.

==

This

==

guide

==

was

==

issued

==

after

==

consideration

==

of

==

comments

==

received

==

from

==

the

==

public.

==

Comments

==

and

==

suggestions

==

for

==

improvements

==

in

==

these

==

guides

==

are

==

encouraged

==

at

==

all

==

times,

==

and

==

guides

==

will

==

be

==

revised,

==

as

==

appropriate,

==

to

==

accommodate

==

comments

==

and

==

to

==

reflect

==

new

==

information

==

or

==

experience.

==

Written

==

comments

==

may

==

be

==

submitted

==

to

==

the

==

Rules

==

and

==

Directives

==

Branch,

==

ADM,

==

U.S.

==

Nuclear

==

Regulatory

==

Commission,

==

Washington,

==

DC

==

20555-0001.

==

Regulatory

==

guides

==

are

==

issued

==

in

==

ten

==

broad

==

divisions:

==

1,

==

Power

==

Reactors;

==

2,

==

Research

==

and

==

Test

==

Reactors;

==

3,

==

Fuels

==

and

==

Materials

==

Facilities;

==

4,

==

Environmental

==

and

==

'*-

==

Siting;

==

5,

==

Materials

==

and

==

Plant

==

Protection;

==

6,

==

Products;

==

7,

==

Transportation;

==

8,

==

Occupational

==

Health;

==

9,

==

Antitrust

==

and

==

Financial

==

Review;

==

and

==

10,

==

General.

==

Single

==

copies

==

of

==

regulatory

==

guides

==

(which

==

may

==

be

==

reproduced)

==

may

==

be

==

obtained

==

free

==

of

==

charge

==

by

==

writing

==

the

==

Distribution

==

Services

==

Section,

==

U.S.

==

Nuclear

==

Regulatory

==

Commission,

==

Washington,

==

DC

==

20555-0001,

==

or

==

by

==

fax

==

to

==

(301)415-2289,

==

or

==

by

==

email

==

to

==

DISTRIBUTION@NRC.GOV.

==

Many

==

regulatory

==

guides

==

are

==

also

==

available

==

on

==

the

==

internet

==

at

==

NRC's

==

home

==

page

==

at

==

<WWW.NRC.GOV>.

==

~c~&

==

~s(7H

==

This

==

guide

==

describes

==

a

==

method

==

acceptable

==

to

==

the

==

NRC

==

staff

==

for

==

complying

==

with

==

the

==

NRC's

==

regulations

==

for

==

ensuring

==

that

==

setpoints

==

for

==

safety-related

==

instrumentation

==

are

==

initially

==

within

==

and

==

remain

==

within

==

the

==

technical

==

specification

==

limits.

==

The

==

guide

==

is

==

being

==

revised

==

to

==

endorse

==

Part

==

1

==

of

==

ISA-S67.04-1994,

==

"Setpoints

==

for

==

Nuclear

==

Safety-Related

==

Instrumentation."2

==

This

==

standard

==

provides

==

a

==

basis

==

for

==

establishing

==

setpoints

==

for

==

nuclear

==

instrumentation

==

for

==

safety

==

systems

==

and

==

addresses

==

known

==

contributing

==

errors

==

in

==

the

==

channel.

==

The

==

information

==

collections

==

contained

==

in

==

this

==

regulatory

==

guide

==

are

==

covered

==

by

==

the

==

requirements

==

in

==

10

==

CFR

==

Part

==

50,

==

which

==

were

==

approved

==

by

==

the

==

Office

==

of

==

Management

==

and

==

Budget,

==

approval

==

number

==

3150-0011.

==

The

==

NRC

==

may

==

not

==

conduct

==

or

==

sponsor,

==

and

==

a

==

person

==

is

==

not

==

required

==

to

==

respond

==

to,

==

a

==

collection

==

of

==

information

==

unless

==

it

==

displays

==

a

==

currently

==

valid

==

OMB

==

control

==

number.

==

B.

==

DISCUSSION

==

Instrument

==

setpoint

==

uncertainty

==

allowances

==

and

==

setpoint

==

discrepancies

==

have

==

led

==

to

==

a

==

number

==

of

==

operational

==

problems.

==

Operating

==

experience

==

indicates

==

that

==

setpoints

==

for

==

safety

==

related

==

instrumentation

==

may

==

allow

==

plants

==

to

==

operate

==

outside

==

the

==

limiting

==

conditions

==

of

==

operation

==

specified

==

in

==

their

==

technical

==

specifications.

==

Licensees

==

have

==

discovered

==

conflicts

==

between

==

existing

==

setpoints

==

and

==

engineering

==

calculations.

==

The

==

causes

==

for

==

these

==

setpoint

==

discrepancies

==

were

==

problems

==

with

==

industry

==

practices

==

that

==

led

==

to

==

errors

==

in

==

calibration

==

procedures

==

and

==

a

==

lack

==

of

==

understanding

==

of

==

the

==

relationship

==

of

==

the

==

setpoint

==

to

==

the

==

allowable

==

value.

==

Additional

==

problems

==

noted

==

included

==

varying

==

setpoint

==

methodologies

==

for

==

engineering

==

calculations,

==

a

==

lack

==

of

==

a

==

consistent

==

definition

==

of

==

allowable

==

value

==

between

==

different

==

setpoint

==

methodologies,

==

and

==

improper

==

understanding

==

of

==

the

==

relationship

==

of

==

the

==

allowable

==

value

==

to

==

earlier

==

setpoint

==

terminology,

==

procedures,

==

and

==

operability

==

criteria.

==

Further

==

problems

==

were

==

noted

==

when

==

procedures

==

(the

==

setpoint

==

process)

==

(1)

==

failed

==

to

==

provide

==

an

==

adequate

==

margin

==

between

==

the

==

instrument

==

as-left

==

criteria

==

and

==

the

==

values

==

(trip

==

set

==

point

==

or

==

allowable

==

values)

==

required

==

per

==

the

==

technical

==

specifications,

==

(2)

==

did

==

not

==

always

==

reflect

==

current

==

design

==

criteria,

==

and

==

(3)

==

did

==

not

==

ensure

==

that

==

revised

==

instrument

==

loops

==

were

==

verified

==

to

==

the

==

original

==

design

==

requirements

==

or

==

that

==

instrument

==

modifications

==

were

==

evaluated

==

for

==

their

==

effect

==

on

==

setpoint

==

calculations.

==

It

==

has

==

also

==

been

==

noted

==

that

==

licensees

==

do

==

not

==

typically

==

verify

==

whether

==

setpoint

==

calculation

==

drift

==

assumptions

==

have

==

remained

==

valid

==

for

==

the

==

system

==

surveillance

==

interval.

==

ISA-S67.04

==

was

==

revised

==

in

==

1987

==

to

==

provide

==

clarification

==

and

==

to

==

reflect

==

industry

==

practice.

==

The

==

term

==

"trip

==

setpoint"

==

was

==

made

==

consistent

==

with

==

the

==

terminology

==

used

==

by

==

the

==

NRC

==

staff.

==

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

==

revision

==

of

==

the

==

standard

==

also

==

reflects

==

the

==

Improved

==

Technical

==

Specification

==

program

==

(a

==

cooperative

==

effort

==

between

==

industry

==

and

==

the

==

NRC

==

staff)

==

and

==

reflect

==

current

==

industry

==

practice.

==

This

==

standard

==

provides

==

a

==

basis

==

for

==

establishing

==

setpoints

==

for

==

nuclear

==

instrumentation

==

for

==

safety

==

systems

==

and

==

addresses

==

known

==

contributing

==

2Copies

==

may

==

be

==

obtained

==

from

==

the

==

Instrument

==

Society

==

of

==

America,

==

67

==

Alexander

==

Drive,

==

Research

==

Triangle

==

Park,

==

NC

==

20779.

==

2

==

errors

==

in

==

a

==

particular

==

channel

==

from

==

the

==

process

==

(including

==

the

==

primary

==

element

==

and

==

sensor)

==

through

==

and

==

including

==

the

==

final

==

setpoint

==

device.

==

The

==

term

==

"trip

==

setpoint"

==

is

==

retained

==

in

==

ISA-S67.04-1994.

==

However,

==

Figure

==

1

==

in

==

ISA

==

$67.04-1994

==

(for

==

convenience,

==

this

==

figure

==

has

==

been

==

reproduced

==

as

==

Figure

==

1

==

in

==

this

==

guide)

==

has

==

been

==

revised

==

to

==

depict

==

region

==

"E,"

==

"a

==

region

==

of

==

calibration

==

tolerance."

==

The

==

calibration

==

tolerance

==

uncertainties

==

depicted

==

by

==

region

==

"E"

==

should

==

be

==

defined

==

and

==

accounted

==

for

==

in

==

the

==

licensee's

==

setpoint

==

methodology.

==

A

==

trip

==

setpoint

==

value

==

identified

==

to

==

be

==

outside

==

region

==

"E"

==

regardless

==

of

==

direction

==

requires

==

readjustment

==

to

==

satisfy

==

the

==

setpoint

==

methodology

==

and

==

uncertainties

==

identified

==

in

==

Figure

==

1

==

(acceptable

==

as-left

==

condition).

==

It

==

should

==

be

==

noted

==

that

==

this

==

standard

==

does

==

not

==

define

==

"nominal"

==

trip

==

setpoint.

==

The

==

trip

==

setpoint

==

as

==

depicted

==

in

==

Figure

==

1

==

is

==

consistent

==

with

==

the

==

term

==

"nominal"

==

trip

==

setpoint

==

as

==

shown

==

about

==

a

==

defined

==

calibration

==

tolerance

==

band.

==

Figure

==

1

==

of

==

the

==

standard

==

provides

==

setpoint

==

relationships

==

for

==

nuclear

==

safety-related

==

setpoints.

==

The

==

figure

==

denotes

==

relative

==

position

==

and

==

not

==

direction,

==

but

==

it

==

should

==

be

==

noted

==

that

==

the

==

uncertainty

==

relationships

==

depicted

==

by

==

Figure

==

1

==

do

==

not

==

represent

==

any

==

one

==

particular

==

method

==

(direction,

==

combination,

==

or

==

relationship

==

of

==

uncertainty

==

groupings)

==

for

==

the

==

development

==

of

==

a

==

trip

==

setpoint

==

or

==

allowable

==

value.

==

Section

==

4

==

of

==

ISA-$67.04-1994

==

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

==

by

==

the

==

licensee

==

should

==

be

==

consistent

==

with

==

the

==

standard

==

and

==

should

==

consider

==

applicable

==

uncertainties

==

regardless

==

of

==

the

==

setpoint

==

application.

==

Additionally,

==

S-

==

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."3

==

The

==

industry

==

consensus

==

standard

==

ANSI/ANS-10.4-1987,

==

"Guidelines

==

for

==

the

==

Verification

==

and

==

Validation

==

of

==

Scientific

==

and

==

Engineering

==

Computer

==

Programs

==

for

==

the

==

Nuclear

==

Industry,"

==

provides

==

helpful

==

information

==

on

==

the

==

qualification

==

of

==

setpoint

==

methodology

==

software.

==

ISA-$67.04-1982

==

has

==

been

==

used

==

by

==

licensees

==

for

==

setpoint

==

methodology

==

and

==

instrument

==

drift

==

evaluations.

==

ISA-$67.04-1994

==

provides

==

limited

==

guidance

==

on

==

drift

==

evaluations

==

and

==

uncertainty

==

term

==

development

==

for

==

the

==

evaluation

==

of

==

an

==

instrument

==

surveillance

==

interval.

==

The

==

3Single

==

copies

==

of

==

regulatory

==

guides,

==

both

==

active

==

and

==

draft,

==

may

==

be

==

obtained

==

free

==

of

==

charge

==

by

==

writing

==

the

==

Office

==

of

==

Administration,

==

Attn:

==

Reproduction

==

and

==

Distribution

==

Services

==

Section,

==

U.S.

==

Nuclear

==

Regulatory

==

Commission,

==

Washington,

==

DC

==

20555,

==

or

==

by

==

fax

==

to

==

(301)415-2289,

==

or

==

by

==

email

==

to

==

<DISTRIBUTION@NRC.GOV>.

==

Copies

==

are

==

also

==

available

==

for

==

inspection

==

or

==

copying

==

for

==

a

==

fee

==

from

==

the

==

NRC

==

Public

==

Document

==

Room

==

at

==

2120

==

L

==

Street

==

NW.,

==

Washington,

==

DC;

==

the

==

PDR's

==

mailing

==

address

==

is

==

Mail

==

Stop

==

LL-6,

==

Washington,

==

DC

==

20555;

==

telephone

==

(202)634-3273;

==

fax

==

(202)634-3343.

==

3

==

Safety

==

Limit

==

Analytical

==

Limit

==

AL

==

Note:

==

This

==

figure

==

is

==

intended

==

to

==

provide

==

relative

==

position

==

and

==

not

==

to

==

imply

==

direction.

==

A

==

t

==

C

==

Allowable

==

Value

==

AL

==

(LSSS)

==

B

==

Trip

==

Setpoint

==

(LSSS)

==

k

==

I

==

E

==

D

==

I

==

Normal

==

A.

==

Allowance

==

described

==

in

==

paragraph

==

4.3.1

==

B.

==

Allowance

==

described

==

in

==

paragraph

==

4.3.1

==

C.

==

Region

==

where

==

channel

==

may

==

be

==

determined

==

inoperable

==

D.

==

Plant

==

operating

==

margin

==

E.

==

Region

==

of

==

calibration

==

tolerance

==

(acceptable

==

as

==

left

==

condition)

==

described

==

in

==

paragraph

==

4.3.1

==

Figure

==

1.

==

Nuclear

==

Safety-Related

==

Setpoint

==

Relationships

==

(Reproduced

==

from

==

ISA-67.04-1994)

==

4

==

staff

==

has

==

generally

==

accepted

==

drift

==

evaluations

==

based

==

on

==

statistical

==

prediction

==

techniques.

==

However,

==

significant

==

variability

==

has

==

been

==

observed

==

in

==

licensees'

==

surveillance

==

interval

==

evaluations

==

with

==

regard

==

to

==

drift,

==

setpoint

==

methodology,

==

and

==

completeness.

==

The

==

following

==

concerns

==

were

==

identified

==

during

==

the

==

NRC

==

staff

==

review,

==

but

==

they

==

have

==

been

==

resolved

==

during

==

the

==

development

==

of

==

ISA-S67.04-1994.

==

==

Limited

==

instrument

==

drift

==

data

==

were

==

included

==

in

==

the

==

licensee

==

setpoint

==

study.

==

==

Drift

==

data

==

account

==

for

==

all

==

data

==

points

==

from

==

a

==

surveillance

==

calibration

==

(i.e.,

==

nine-point

==

check)

==

as

==

independent

==

data,

==

but

==

inadequate

==

justification

==

is

==

provided

==

for

==

this

==

assumption.

==

Drift

==

data

==

points

==

also

==

included

==

interim

==

calibrations.

==

==

A

==

large

==

number

==

of

==

data

==

points

==

was

==

provided

==

for

==

a

==

limited

==

number

==

of

==

instruments.

==

==

Flawed

==

outlier

==

analysis

==

resulted

==

in

==

valid

==

data

==

being

==

removed

==

from

==

the

==

data

==

set.

==

==

Drift

==

dependency

==

on

==

time

==

was

==

assumed

==

to

==

be

==

negligible

==

over

==

the

==

interval

==

selected,

==

and

==

inadequate

==

justification

==

was

==

provided

==

when

==

extrapolating

==

to

==

an

==

extended

==

surveillance

==

interval

==

(e.g.,

==

24

==

months).

==

==

Setpoint

==

methodology

==

assumes

==

normal

==

distribution

==

of

==

data

==

when

==

such

==

an

==

assumption

==

was

==

not

==

verified.

==

0

==

Instrumentation

==

evaluations

==

(historical,

==

maintenance,

==

drift)

==

were

==

incomplete.

==

0

==

Drift

==

projections,

==

including

==

those

==

based

==

on

==

regression

==

analyses,

==

may

==

not

==

account

==

for

==

penalties

==

for

==

uncertainty

==

projection

==

(extended

==

surveillance

==

interval-drift)

==

beyond

==

the

==

time

==

range

==

for

==

the

==

data

==

collected.

==

==

Instrument

==

application

==

and

==

process

==

or

==

installation

==

variables

==

were

==

not

==

evaluated.

==

==

The

==

uncertainties

==

assumed

==

for

==

instrumentation,

==

including

==

primary

==

elements,

==

were

==

subsequently

==

not

==

verified

==

or

==

controlled

==

through

==

surveillance

==

testing,

==

qualification,

==

or

==

maintenance

==

programs.

==

==

The

==

acceptability

==

of

==

pooling

==

generic

==

drift

==

data

==

with

==

plant-specific

==

data

==

or

==

weighing

==

the

==

data

==

according

==

to

==

the

==

source

==

of

==

the

==

data

==

was

==

not

==

justified.

==

==

All

==

available

==

applicable

==

data

==

were

==

not

==

utilized

==

in

==

the

==

analysis.

==

Section

==

4.3

==

of

==

ISA-S67.04-1994

==

states

==

that

==

the

==

limiting

==

safety

==

system

==

setting

==

(LSSS)

==

may

==

be

==

the

==

trip

==

setpoint,

==

an

==

allowable

==

value,

==

or

==

both.

==

For

==

the

==

standard

==

technical

==

specifications,

==

the

==

staff

==

designated

==

the

==

allowable

==

value

==

as

==

the

==

LSSS.

==

In

==

association

==

with

==

the

==

trip

==

setpoint

==

and

==

limiting

==

conditions

==

for

==

operation

==

(LCOs),

==

the

==

LSSS

==

establishes

==

the

==

threshold

==

for

==

protective

==

system

==

action

==

to

==

prevent

==

acceptable

==

limits

==

being

==

exceeded

==

during

==

design

==

basis

==

accidents.

==

The

==

LSSS

==

therefore

==

ensures

==

that

==

automatic

==

protective

==

action

==

will

==

correct

==

the

==

abnormal

==

situation

==

before

==

a

==

safety

==

limit

==

is

==

exceeded.

==

A

==

licensee,

==

with

==

justification,

==

may

==

propose

==

an

==

alternative

==

LSSS

==

based

==

on

==

its

==

particular

==

setpoint

==

methodology

==

or

==

license.

==

5

==

The

==

standard

==

provides

==

for

==

the

==

accounting

==

of

==

measurement

==

and

==

test

==

equipment

==

(MTE)

==

uncertainties,

==

but

==

MTE

==

criteria

==

are

==

not

==

specifically

==

identified

==

within

==

the

==

standard.

==

Criteria

==

XI

==

and

==

XII

==

in

==

Appendix

==

B

==

to

==

10

==

CFR

==

Part

==

50

==

provide

==

requirements

==

for

==

quality

==

regarding

==

testing.

==

Regulatory

==

Guide

==

1.118,

==

"Periodic

==

Testing

==

of

==

Electric

==

Power

==

and

==

Protection

==

Systems,"

==

provides

==

guidance

==

on

==

periodic

==

surveillance

==

testing.

==

Part

==

II,

==

"Methodologies

==

for

==

the

==

Determination

==

of

==

Setpoints

==

for

==

the

==

Nuclear

==

Safety

==

Related

==

Instrumentation,"

==

of

==

ISA-$67.04-1994

==

is

==

not

==

addressed

==

by

==

this

==

regulatory

==

guide.

==

C.

==

REGULATORY

==

POSITION

==

Conformance

==

with

==

Part

==

1

==

of

==

ISA-S67.04-1994,

==

"Setpoints

==

for

==

Nuclear

==

Safety-Related

==

Instrumentation,"

==

2

==

with

==

the

==

following

==

exceptions

==

and

==

clarifications,

==

provides

==

a

==

method

==

acceptable

==

to

==

the

==

NRC

==

staff

==

for

==

satisfying

==

the

==

NRC's

==

regulations

==

for

==

ensuring

==

that

==

setpoints

==

for

==

safety-related

==

instrumentation

==

are

==

established

==

and

==

maintained

==

within

==

the

==

technical

==

specification

==

limits.

==

1.

==

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.

==

2.

==

Sections

==

7

==

and

==

8

==

of

==

Part

==

1

==

of

==

ISA-S67.04-1994

==

reference

==

several

==

industry

==

codes

==

and

==

standards.

==

If

==

a

==

referenced

==

standard

==

has

==

been

==

incorporated

==

separately

==

into

==

the

==

NRC's

==

regulations,

==

licensees

==

and

==

applicants

==

must

==

comply

==

with

==

that

==

standard

==

as

==

set

==

forth

==

in

==

the

==

regulation.

==

If

==

the

==

referenced

==

standard

==

has

==

been

==

endorsed

==

in

==

a

==

regulatory

==

guide,

==

the

==

standard

==

constitutes

==

a

==

method

==

acceptable

==

to

==

the

==

NRC

==

staff

==

of

==

meeting

==

a

==

regulatory

==

requirement

==

as

==

described

==

in

==

the

==

regulatory

==

guide.

==

If

==

a

==

referenced

==

standard

==

has

==

been

==

neither

==

incorporated

==

into

==

the

==

NRC's

==

regulations

==

nor

==

endorsed

==

in

==

a

==

regulatory

==

guide,

==

licensees

==

and

==

applicants

==

may

==

consider

==

and

==

use

==

the

==

information

==

in

==

the

==

referenced

==

standard

==

if

==

appropriately

==

justified,

==

consistent

==

with

==

current

==

regulatory

==

practice.

==

3.

==

Section

==

4.3

==

of

==

ISA-$67.04-1994

==

states

==

that

==

the

==

limiting

==

safety

==

system

==

setting

==

(LSSS)

==

may

==

be

==

maintained

==

in

==

technical

==

specifications

==

or

==

appropriate

==

plant

==

procedures.

==

However,

==

10

==

CFR

==

50.36

==

states

==

that

==

the

==

technical

==

specifications

==

will

==

include

==

items

==

in

==

the

==

categories

==

of

==

safety

==

limits,

==

limiting

==

safety

==

system

==

settings,

==

and

==

limiting

==

control

==

settings.

==

Thus,

==

the

==

LSSS

==

may

==

not

==

be

==

maintained

==

in

==

plant

==

procedures.

==

Rather,

==

the

==

LSSS

==

must

==

be

==

specified

==

as

==

a

==

technical-specification-defined

==

limit

==

in

==

order

==

to

==

satisfy

==

the

==

requirements

==

of

==

10

==

CFR

==

50.36.

==

The

==

LSSS

==

should

==

be

==

developed

==

in

==

accordance

==

with

==

the

==

setpoint

==

methodology

==

set

==

forth

==

in

==

the

==

standard,

==

with

==

the

==

LSSS

==

listed

==

in

==

the

==

technical

==

specifications.

==

4.

==

ISA-$67.04-1994

==

provides

==

a

==

discussion

==

on

==

the

==

purpose

==

and

==

application

==

of

==

an

==

allowable

==

value.

==

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.

==

The

==

6

==

allowable

==

value

==

relationship

==

to

==

the

==

setpoint

==

methodology

==

and

==

testing

==

requirements

==

in

==

the

==

technical

==

specifications

==

must

==

be

==

documented.

==

D.

==

IMPLEMENTATION

==

The

==

purpose

==

of

==

the

==

section

==

is

==

to

==

provide

==

information

==

to

==

applicants

==

and

==

licensees

==

regarding

==

the

==

NRC

==

staffs

==

plans

==

for

==

using

==

this

==

regulatory

==

guide.

==

Except

==

in

==

those

==

cases

==

in

==

which

==

an

==

applicant

==

or

==

licensee

==

proposes

==

an

==

acceptable

==

alternative

==

method

==

for

==

complying

==

with

==

specified

==

portions

==

of

==

the

==

NRC's

==

regulations,

==

the

==

methods

==

described

==

in

==

this

==

guide

==

will

==

be

==

used

==

in

==

the

==

evaluation

==

of

==

submittals

==

in

==

connection

==

with

==

applications

==

for

==

construction

==

permits,

==

operating

==

licenses,

==

and

==

combined

==

licenses.

==

It

==

will

==

also

==

be

==

used

==

to

==

evaluate

==

submittals

==

from

==

operating

==

reactor

==

licensees

==

who

==

voluntarily

==

propose

==

to

==

initiate

==

system

==

modifications

==

if

==

there

==

is

==

a

==

clear

==

nexus

==

between

==

the

==

proposed

==

modifications

==

and

==

this

==

guidance.

==

VALUE/IMPACT

==

STATEMENT

==

A

==

draft

==

value/impact

==

statement

==

was

==

published

==

with

==

the

==

draft

==

proposed

==

Revision

==

3

==

of

==

this

==

guide

==

when

==

it

==

was

==

published

==

for

==

public

==

comment

==

(DG-1045,

==

October

==

1996).

==

No

==

changes

==

were

==

necessary,

==

so

==

a

==

separate

==

value/impact

==

statement

==

for

==

the

==

final

==

guide

==

has

==

not

==

been

==

prepared.

==

A

==

copy

==

of

==

the

==

draft

==

value/impact

==

statement

==

is

==

available

==

for

==

inspection

==

or

==

copying

==

for

==

a

==

fee

==

in

==

the

==

NRC's

==

Public

==

Document

==

Room

==

at

==

2120

==

L

==

Street

==

NW.,

==

Washington,

==

DC

==

under

==

task

==

DG-1045.

==

7

==

)

==

N

==

UNITED

==

STATES

==

NUCLEAR

==

REGULATORY

==

COMMISSION

==

WASHINGTON,

==

DC

==

20555-0001

==

OFFICIAL

==

BUSINESS

==

PENALTY

==

FOR

==

PRIVATE

==

USE,

==

$300