ISA Set Point Methadology

B iw babcock & wilcox rnPower
1 109 ramsey place I- lynchburg, va 24501 P phone 434.316.7592

, tfax 434.316.7534 I www.babcock.com
January 9, 2013 MPWR-LTR-12-00101
U.S. Nuclear Regulatory Commission (NRC)
ATTN: Document Control Desk
11555 Rockville Pike
Rockville, MD 20852-2738
Babcock & Wilcox mPower, Inc.
Docket Number-PROJO776
Project Number-776
Subject: Submittal of Babcock and Wilcox mPower, Inc. (B&W mPower) Instrument Setpoint
Methodology Topical Report R0003-08-002089-A, Revision 003
References:
1. Letter from Jeffrey A. Halfinger, et al (B&W Nuclear Energy, Inc.) to NRC, Submittal of
Babcock & Wilcox Nuclear Energy, Inc. (B&W NE) Instrument Setpoint Methodology Topical
Report (Report Number 08-002089-000), October 28, 2010
2. Letter from Jeffrey A. Halfinger (B&W Nuclear Energy, Inc.) to NRC, Submittal of Babcock &
Wilcox Nuclear Energy, Inc. (B&W NE) Instrument Setpoint Methodology Topical Report
Revision 1 (Report Number 08-002089-001), June 30, 2011
3. Email from Jan Mazza (NRC) to Jeffrey A. Halfinger et al (B&W mPower), Request for
Additional Information Letter No. 4 for the Review of Babcock & Wilcox (B&W) mPower
Reactor Project Instrument Setpoint Methodology Topical Report 08-002-2089 [sic]
Revision 1 (TAC No. RN6113), December 22, 2011
4. Letter from Jeffrey A. Halfinger (B&W Nuclear Energy, Inc.) to NRC, Babcock & Wilcox
Nuclear Energy, Inc. (B&W NE) Response to NRC Request for Additional Information,
February 2, 2012
5. Letter from Jeffrey A. Halfinger (B&W Nuclear Energy, Inc.) to NRC, Babcock & Wilcox
Nuclear Energy, Inc. (B&W NE) Revised Response to Request for Additional Information
No. 6236, RAI Letter No. 4 for Appendices 5, 6. 9, 11 and 13, May 21, 2012
6. Letter from Michael E. Mayfield (NRC) to Jeffrey A. Halfinger (B&W mPower), Final Safety
Evaluation for Babcock & Wilcox mPower, Inc. Topical Report TROO03-08-002089,
Revision 3, "Instrument Setpoint Methodology Topical Report" (TAC No. RN6113),
October 12, 2012
Topical Report (TR) 08-002089-000, Revision 0, Instrument Setpoint Methodology Topical Report,
(Reference 1) was submitted for NRC review and approval by then B&W NE on October 28, 2010.
The TR was subsequently revised on the basis of preliminary feedback from the NRC staff, and
Revision 1 of the report was submitted on June 30, 2011 (Reference 2).
babcock & wilcox mPower, Inc., a Babcock & Wilcox company
U.S Nuclear Regulatory Commission
MPWR-LTR-12-00101
January 9, 2013
Page 2
By email dated December 22, 2011 (Reference 3), the NRC forwarded Request for Additional
Information (RAI) No. 6236 (RAI Letter No. 4) that contained thirteen questions. B&W mPower
provided its response to the RAI in a letter dated February 2, 2012 (Reference 4) that included
proposed clarifications and changes to the TR. In a conference call on March 3, 2012, the NRC
requested clarifications to portions of the B&W mPower response, and B&W provided a revised RAI
response by letter dated May 21, 2012 (Reference 5). That letter also forwarded Revision 3 of the
TR that incorporated changes consistent with the revised RAI response.
By letter dated October 12, 2012 (Reference 6), the NRC issued its final safety evaluation for
Revision 3 of TROO03-08-002089 documenting the staff conclusion that this version of the report
adequately described the B&W mPower Instrument Setpoint Methodology, and that the
methodology complied with the applicable NRC regulations and industry standards.
The NRC's October 12, 2012 letter also requested that B&W mPower publish the accepted version
(Revision 3) of TROO03-08-002089 within three months of the receipt thereof. Accordingly, the
enclosure to this letter provides the B&W mPower R0003-08-002089-A, Revision 003, "Instrument
Setpoint Methodology Topical Report." This approved version of the TR incorporates the October
12, 2012 NRC letter and its enclosed final safety evaluation following the TR cover page (with the
document number reflecting the report's approved status). The TR with the revised document
number is included at the very end of the enclosure. The approved TR also provides historical
review information including the letters to and from the NRC, the NRC's RAIs, and B&W mPower
response to the RAls (References 1 through 5). A table of contents following the cover page is
provided to assist in locating the referenced historical documents.
Questions concerning this letter may be directed to Jeff Halfinger at 434-316-7507 (email:
iahalfinaerO-babcock.com)
or Peter Hastings at 980-365-2071 (email:
pshastingscf.enerationm power.com).
VP, NSSS Technology
B&W mPower
JAH/jlr
Enclosure: Babcock and Wilcox mPower Instrument Setpoint Methodology Topical Report
R0003-08-002089-A, Revision 003
cc: Joelle L. Starefos, NRC, TWFN 9-F-27
Stewart L. Magruder, Jr., NRC, TWFN 9-F-27
babcock & wilcox mPower, Inc., a Babcock & Wilcox company
Document No: Title:
Rev:
R0003-08-002089-A Instrument Setpoint Methodology Topical Report 003
Instrument Setpoint Methodology Topical Report
R0003-08-002089-A
January 2013
Revision 003
a progressive energy solution
B&W mPowerTM Reactor Program
109 Ramsey Place
Lynchburg, VA 24501
2012 Babcock & Wilcox mPower, Inc. All rights reserved.
TABLEOF CONTENTS
SECTION, DESCRIPTION PAGE
Letter from Michael E. Mayfield (NRC) to Jeffrey A. Halfinger
(B&W mPower), Final Safety Evaluation for Babcock & Wilcox
Section A mPower, Inc, Topical Report TR0003-08-002089, Revision 3, 3 of 113
"Instrument Setpoint Methodology Topical Report" (TAC No.
RN6113), October 12, 2012
Letter from Jeffrey A. Halfinger, et al (B&W Nuclear Energy, Inc.).
to NRC, Submittal of Babcock & Wilcox Nuclear Energy, Inc.
Section B (B&W NE) Instrument Setpoint Methodology Topical Report 17 of 1 13
(Report Number 08-002089-000), October 28, 2010 (Without
Revision 000)
Letter from Jeffrey A..Halfinger (B&W NuclearEnergy, Inc.) to
NRC, Submittal of Babcock & Wilcox Nuclear Energy, Inc. (B&W
Section C NE) Instrument Setpoint Methodology Topical Report Revision 1 19 of 113
(Report Number 08-002089-001), June 30, 2011 (Without
Revision 1)
Email from Jan Mazza (NRC) to Jeffrey A. Halfinger et al (B&W
mPower), Request for Additional Information Letter No. 4 for the
Section D Review of Babcock & Wilcox (B&W) mPower Reactor Project
Instrument. Setpoint Methodology Topical Report 08-002-2089-
[sic] Revision 1 (TAC No. RN6113), December 22, 2011
Letterfrom'Jeffrey A. Halfinger (B&W Nuclear Energy, Inc.) to
NRC, Babcock & Wilcox Nuclear Energy,. Inc. (B&W:NE)
Section E Response.to NRC Request for Additional Information, 29 of 113
February 2, 2012
Letter from Jeffrey A. Halfinger (B&W Nuclear Energy, Inc.) to
NRC, Babcock & Wilcox Nuclear Energy, Inc, (B&W NE) Revised
Response to Request for Additional Information No. 6236, RAI
Letter No. 4for Appendices 5, 6.9, 11 and 13, May 21, 2012.
Section F (Enclosure 3 to letter included the Revision 003 to R003-08- 52 of 113
002089 which was accepted in the Safety. Evaluation provided.in
the October 12, 2012 letter. That enclosure is not included here
but provided as a "-A" version in Section G.)
B&W mPower Inc. R0003-08-002089-A, Revision 003,
Section G "Instrument Setpoint Methodology Topical Report
75 of. 13
R0003-08-002089-A Page 2 of 113 January-2013, Revision 3
Section A
R0003-08-002089-A
Page 3 of 113 January 2013, Revision 3
October 12, 2012
Mr. Jeffrey A. Halfinger, Vice President
NSSS Technology Development
109 Ramsey Place
Lynchburg, VA 24501
SUBJECT: FINAL SAFETY EVALUATION FOR BABCOCK & WILCOX MPOWER, INC.
TOPICAL REPORT TROO03-08-002089, REVISION 3, "INSTRUMENT
SETPOINT METHODOLOGY TOPICAL REPORT" (TAC NO. RN6113)
Dear Mr. Halfinger:
On October 28, 2010, Babcock & Wilcox Company (B&W) Nuclear Energy Inc. (predecessor of
Babcock & Wilcox mPower, Inc.), submitted to the U.S Nuclear Regulatory Commission (NRC)
Topical Report (TR) 08-002089, Revision 0, "Instrument Setpoint Methodology," for the Design
Certification of the B&W mPowerTM Reactor to the N RC staff for review (Agencywide
Documents Access and Management System (ADAMS) Accession Number ML103020473). By
letter dated June 30, 2011, B&W submitted Topical Report 08-002089-01, Revision 1,
"Instrument Setpoint Methodology," for the Design Certification of the B&W mPowerTM Reactor
to the NRC staff for review (ADAMS Accession Numbers ML1 11 82C034 and ML1 11 82C035).
By letters dated February 2, 2012 and May 21, 2012, B&W responded to the NRC staff requests
for additional information, and transmitted Revision 3 of Topical Report 08-002089-003 (ADAMS
Accession Numbers ML12037A001, ML12153A304, and ML12143A424). By letter dated
August 15, 2012, an NRC draft safety evaluation (SE) regarding our approval of TROO03-08-
002089, Revision 3, was provided for your comments on any factual errors or clarity concerns
(ADAMS ML12222A058). By letter dated August 23, 2012, B&W commented on the staff draft
SE.(ADAMS ML12237A281). The NRC staffs disposition of-the B&W mPower, Inc. comments
on the draft SE are addressed in the final SE enclosed with this letter.
On the basis of its review, the NRC staff concludes that Revision 3 of the B&W mPower, Inc.
Instrument Setpoint Methodology Topical Report (TR), as documented in the referenced letters,
adequately describes the B&W mPower Inc. Instrument Setpoint Methodology. Accordingly, the
NRC staff finds that the B&W mPower, Inc. Instrument Setpoint Methodology complies with the
applicable NRC regulations and industry standards.
The enclosed SE defines the basis for acceptance of the TR. Our acceptance applies only to
material provided and we do not intend to repeat our review of the acceptable material
described in the TR. When the TR appears as a reference in regulatory applications, our review
will ensure.that the material presented applies to the specific application involved. Licensing
requests that deviate from this TR will be subject to a plant- or site-specific review in
accordance with applicable review standards.
R0003-08-002089-A
Page 4 of 113.
January 2013, Revision 3
J. Halfinger
-2-.
In accordance with the guidance provided on the NRC website, we request that B&W mPower,
Inc. publish the accepted version of this TR within 3 months of receipt of this letter. The
accepted version.shall incorporate this letter and the enclosed SE after the title page.
Also, the accepted version must contain historical review information, including NRC requests
for additional information and your responses after the title page. The accepted versions shall*
include a "-A" (designating accepted) following the TR identification symbol.
As an alternative to including the requests for additional information (RAIs) and RAI responses
behind the title page, if changes to the TR were provided to the NRC staff to support the
resolution of RAI responses, and the NRC staff reviewed and approved those changes as
described in the RAI responses, there are two ways that the accepted version can capture the
RAIs:
1. The RAIs and RAI responses can be included as an Appendix to the accepted version.
2. The RAIs and RAI responses can be captured in the form of a table (inserted after the
final SE) which summarizes the changes as shown in the approved version of the TR.
The table should reference the specific RAIs and RAlresponses which resulted in any
changes, as shown in the accepted version of the TR.
If future changes to the NRC's regulatory requirements affect the acceptability of this TR, B&W
mPower, Inc. and/or licensee's referencing it will be expected to revise the'TR appropriately, or
justify its continued applicability for subsequent referencing.
If you have any questions, please contact Jan Mazza at (301) 415-0498, email
Jan.Mazza@nrc.gov, or Joelle Starefos at (301) 415-6091, email Joelle.Starefos@nrc.gov.
Sincerely,
IRA!
Michael E. Mayfield, Director
Division of Advanced Reactors and Rulemaking
Office of New Reactors
Project No.: 0776
Enclosure:
Final Safety Evaluation
DISTRIBUTION:
PUBLIC RidsNroDarrResource RidsAcrsAcnw_MailCenter
RidsRgn2MailCenter RidsNroDelcbResource RidsOgcMailCenterResource
ADAMS Accession No.: ML12278A349 *via email NRO-002
OFFICE PM:NRO/DARR/APRB PM:NRO/DARR/APRB GE:NRO/DE/ICB BC:NRO/DE/ICB
NAME JMazza JStarefos JAshcraft Jung
DATE 10/4/12 10/9/12 10/10/12 10/10/12
OFFICE BC:NRO/DARR/APRB OGC* (NLO) D:NRO/DARR;
NAME SMagruder MLewis MMayfield(JColaccino for)'
DATE 110/11/12 10/3/12 10/12/12
R0003-08-002089-A Page 5 of 113
FINAL SAFETY EVALUATION REPORT FOR BABCOCK & WILCOX MPOWER, INC.TOPICAL
REPORT. R0003-08-002089, REVISION 3, "INSTRUMENT SETPOINT
METHODOLOGY TOPICAL REPORT" (TAC NO. RN6113)
PROJECT NO. 0776
1.0 INTRODUCTION AND BACKGROUND
On October 28, 2010, Babcock & Wilcox Company (B&W) Nuclear Energy Inc. (predecessor of
Babcock & Wilcox mPower, Inc.), submitted to the Nuclear Regulatory Commission (NRC)
Topical Report (TR) 08-002089, Revision 0, "Instrument Setpoint Methodology," for technical
staff review (Reference 1). The NRC staff identified areas for further discussion and transmitted
them to B&W (Reference 2). B&W resubmitted TR 08-002089, Revision 1 (Reference 3) for
acceptance review and was accepted by the NRC (Reference 4). Revision 2 of TR 08-002089
was not submitted to the NRC.
The staff submitted "Request for Additional Information No. 6236 RAI Letter No. 4" dated
December 22, 201.1 (Reference 5). The B&W response to RAIs 07.01-C Appendix-1 through 13
was submitted and incorporated into TR R0003-08-002089, Revision 3, by letters dated
February 2 (Reference 6) and May 21, 2012 (Reference 7,).
B&W states that the B&W TR details the instrument setpoint methodology applied to the reactor
protection system (RPS) setpoints and other important instrument setpoints associated with the
B&W mPowerrm reactor. The RPS is a digital, integrated reactor protection and engineered
safety features actuation system implemented for the B&W mPowerTM reactor. The
methodology described in this topical report is used to establish technical specification setpoints
for the B&W mPowerTM RPS in accordance with 10 CFR 50.36.
The methodology described in this report is for the uncertainty analysis, setpoint determination,
and determination of allowable values that protect analytical limits as applied to safety-related
equipment that perform specific safety functions. Typical instrument setpoints in this category
are established for equipment that supports reliable power generation or equipment protection.
The results of the uncertainty evaluations can be applied to the following types of calculations:
* Determination of safety-related setpoints;
* Extension of surveillance intervals;
* Determination of instrument indication uncertainties; and/or
* Evaluation or justification of previously established setpoints.
Determination of instrument setpoints using this methodology for non-safety related
equipment that does not perform a specific safety function as discussed above, is
controlled administratively by plant procedures.
Enclosure
R0003-08-002089-A
Page 6 of 113
2.0 REGULATORY BASIS
The following regulatory requirements and guidance documents are applicable to the staffs
review of the TR R0003-08-002089:
Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, General Design
Criterion (GDC) 13, "Instrumentation and Control," requires, in part, that instrumentation be
provided to monitor variables and systems over their anticipated ranges for, normal operation,
for anticipated operational occurrences, and for accident conditions as appropriate to assure
adequate safety, and that appropriate controls be provided to maintain these variables and
systems within prescribed operating ranges.
10 CFR Part 50, Appendix A, GDC 20, "Protection System Functions," requires, in part, that the
protection system be designed to initiate operation of appropriate systems to ensure that
specified acceptable fuel design limits are not exceeded as a result of anticipated operational
occurrences.
10 CFR Part 50, Appendix B, Criterion XI, "Test Control," and Criterion XII, "Control of
Measuring and Test Equipment," provide requirements for tests and test equipment used in
maintaining instrument setpoints.
10 CFR 50.36(c)(1)(ii)(A) requires, in part, that if a limiting safety system setting (LSSS) is
specified for a variable on which a safety limit has been placed, the setting be chosen so that
automatic protective action will correct the abnormal situation before a safety level is exceeded.
LSSSs are settings for automatic protective devices related to variables with significant safety
functions. Additionally, 10 CFR 50.36(c)(1)(ii)(A) requires that a licensee take appropriate action
if it is determined 'that the automatic safety system does not function as required. ,
10 CFR 50.36(c)(3), "Technical Specifications," states that surveillance requirements are
requirements relating to, test, calibration, or inspection to assure that the necessary quality of
systems and components is maintained, that facility operation will be within safety- limits, and
that the limiting conditions for operation will be met.
10 CFR 50.55a(h), "Protection and Safety Systems," requires compliance with IEEE
Std. 603-1991, "IEEE Standard Criteria for Safety Systems for Nuclear PowerGenerating
Stations,". and the correction sheet dated January 30, 1995. Clause 6.8.1 of IEEE Std. 603-
1991, requires that allowances for uncertainties between the analytical limit of the safety system
and device setpoint be determined using a documented methodology.
-2-
R0003-08-002089-A Page 7 of 113 January 2013, Revision 3
3.0 RELEVENT GUIDANCE
Regulatory Guide (RG) 1.105, Revision 3, "Setpoints for Safety-Related Instrumentation,"
provides guidance for ensuring that instrument setpoints for safety-related instrumentation are
initially - and remain - within the technical specification limits. This RG endorses ISA-$67.04-
1994, Part I, "Setpoints for Nuclear Safety-Related Instrumentation," with clarifications.
ISA-S67.04-1994, Part II, "Methodology for the Determination of Setpoints for Nuclear Safety-
Related Instrumentation," provides additional guidance, but RG 1.105, Revision 3, does not
endorse or address Part II of ISA-S67.04-1994.
In NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Report for Nuclear
Power Plants: Light Water Edition," (SRP) section entitled, Branch Technical Position (BTP) 7-
12, "Guidance on Establishing and Maintaining Instrument Setpoints," Revision 5, March 2007,
there are guidelines for reviewing the process an applicant/licensee follows to establish and
maintain instrument setpoints.
NRC Regulatory Issue Summary (RIS) 2006-17, "NRC Staff Position.on the Requirements of 10
CFR 50.36, 'Technical Specifications,' Regarding Limiting Safety System Settings during
Periodic Testing and Calibration of Instrument Channels," discusses issues that could occur
during testing of LSSSs and which therefore, may have an adverse effect on equipment
operability.
Generic Letter (GL) 91-04, Enclosure 1, "Guidance on Preparation of a License Amendment
Request for Changes in Surveillance Intervals to Accommodate a 24-Month Fuel Cycle,"
provides guidance on issues that should be addressed by the setpoint analysis when calibration
intervals are extended from an 18-month or other refueling outage interval to 24 months.
The objectives of the review of TR R0003-08-002089 are to (1) verify that setpoint calculation
methods are adequate to assure that protective actions are initiated before the associated plant
process parameters exceed their analytical limits, (2) verify that setpoint calculation methods
are adequate to assure that control and monitoring setpoints are consistent with their
requirements, and (3) confirm that the established calibration intervals and methods are
consistent with safety analysis assumptions. The staff evaluated the setpoint methodology
using SRP BTP 7-12 to verify conformance with the previously cited regulatory bases and
standards for instrument setpoints with emphasis on the following:
1. Relationships between the safety limit, the analytical limit, the limiting trip setpoint, the
allowable value, the setpoint, the acceptable as-found band, the acceptable as-left band,
and the setting tolerance.
2. Setpoint technical specifications meeting the requirements of 10 CFR 5036. Additional
information related to setpoint technical specifications is provided in RIS 2006-17.
3. Basis for selection of the trip setpoint.
4. Uncertainty terms that are addressed.
-3-
R0003-08-002089-A
Page 8 of 113
January2013, Revision 3.
5. Method used to combine uncertainty terms.
6. Justification of statistical combination.
7. Relationship between instrument and process measurement units.
8. Data used to select the trip setpoint, including the source of the data.
9. Assumptions used to select the trip setpoint (e.g., ambient temperature limits for equipment
calibration and operation, potential for harsh accident environment).
10. Instrument installation details and bias values that could affect the setpoint.
11. Correction factors used to determine the setpoint (e.g., pressure compensation to account
for elevation difference between the trip measurement point and the sensor physical
location).
Instrument test, calibration or vendor data, as-found and as-left; each instrument should be
demonstrated to have random drift by empirical and field data. Evaluation results should be
reflected appropriately in the uncertainty terms, including the setpoint methodology.
4.0 TECHNICAL EVALUATION
The establishment of setpoints and the relationships between nominal trip setpoints
(NTSPs), limiting trip setpoints (LTSPs), allowable value (AV), as-left values, as-found
values, as-left tolerance (ALT),.as-found tolerance (AFT), analyticallimit (AL), and safety
limit (SL) are discussed in this report. A thorough understanding of these terms is
important in order to properly utilize the total instrument channel uncertainty in the
establishment of setpoints.
The SLs are chosen to protect the integrity of physical barriers that guard against the
uncontrolled release of radioactivity. The SLs are typically provided in the plant safety analyses.
The AL is established to ensure that the SL is not exceeded. The ALs are developed from
event analyses models that consider parameters such as process delays, rod insertion times,
reactivity changes, analysis margin, transient response, modeling error., instrument response
times, etc. and are provided in Chapter 15, "Transient and Accident Analysis," of the design
control document (DCD) of the application. A properly established setpoint initiates a plant
protective action before the process parameter exceeds its AL. This, in turn, assures that the
transient will be, avoided and/or terminated before the process parameters exceed the
established SLs.
This TR is based on following the requirements of RG 1.105, Revision 3, which describes a
method acceptable to the NRC for complying with the applicable regulations. The TR follows
ANSI/ISA-67.04.01-2000 (Reference 8) rather than ISA-S67.04-1994, Part I as endorsed by RG
1.105, Revision 3. The use of ANSI/ISA-67.04.01-2000 proposed -by the TR is acceptable in
lieu of ISA-S67.04-1994, Part I because ANSI/ISA-67.04.01-2000, Section 2, states, "ANSI/ISA
RP67.04.02-2000 is equivalent to ISA-$67.04-1994." This TR also follows the guidance listed in
recommended practice ANSI/ISA-67.04.02-2000.
-4-
R0003-08-002089-A
Page 9 of11,3 R. January 2013, Revision 3
In the B&W methodology, the AL is established to ensure that a trip occurs before the SL
is reached. The purpose of an LSSS is to assure that a protective action is initiated
before the process conditions reach the AL. Trip setpoints are chosen based on the
LSSS and to minimize spurious trips close to the normal operating point of the process.
Figure 5.1 -of the TR shown below provides a pictorial representation of the B&W
setpoint methodology relationships.
-5-
Plant Safety Analysis and Design Basis
SAFETY LIMIT (SL)
ANALYSIS MARGIN, TRANSIENT RESPONSE,
MODELING ERROR, RESPONSE TIME, ETC.
ANALYTIC LIMIT -__---___---__
(AL)
CHANNEL
UNCERTAINTY (CU)
[Equation 4.22]
LIMITING TRIP
SETPOINT (LTSP)
[Equation 4.2.3)
MARGIN
P SETPOINT
(NTSP)
(OE1
I~
Periodic Surveillance Testing
TRIP
[Equation 4.2.31
AS-LEFT
TOLERANCE
(ALT)
ALLOWABLE VALUE (AV)
[Equation 4.2.4]
TOTAL AS-FOUND
TOLERANCE BAND (AFTToT)
(Equation 4.2.51
NORMAL
OPERATING MARGIN (OM)
[Equation 4.2.61
NORMAL OPERATING
UPPER LIMIT (NUL)
OPERATING RANGE
REGION A: Channel is operable, no
calibration is required.
REGION B: Channel is operable, but
degraded. Recalibration is required and must
be evaluated for proper functionality.
REGION C: Channel is inoperable.
* Recalibration is required and must be evaluated
for proper functionality.
REGION D: Channel is inoperable.
* Recalibration is required and must be evaluated
IF
SYSTEM SHUTDOWN
ILLUSTRATION SHOWN FOR
PROCESS PARAMETER
INCREASING TOWARD SETPOINT
AND IS NOT DRAWN TO SCALE
NOTES:
1. There is no set value for margin that is applied to the
CU to determine the NTSP. This margin of safety is a
discretionary value based on engineering judgment to
add conservatism when determining the NTSP, to ensure
protection of the analytical limit. The applied margin
must be greater than or equal to the as-found tolerance
to ensure the AV never exceeds the LSSS.
Figure 5.1: Setpoint Relationships - For Increasing Setpoint (The setpoint relationship is
similar for decreasing setpoints, except that the process is decreasing towards the
setpoint and AL).
-6-
R0003-08-002089-A
Note: This figure is intended to provide relative position and not to imply direction..
Sections 4.1.5 and 4.2.3, of the TR defines LTSP as an LSSS and also defines NTSP as the
desired value of the measured variable at which an actuation occurs. The calculation of the
LTSP value is set forth in Section 4.2.3 of the TR as LTSP = AL+/- CU, where CU is the total
channel uncertainty. Note 1 on Figure 5.1 of the TR defines AV such that it will never exceed
the LTSP (LSSS) and in most cases should be more conservative than the LTSP. The
calculation of the AV is set forth in Section 4.2.4 of TR as AV = NTSP +/- AFTTOT where
AFTTOT is the total AFT for the entire instrument channel. The NTSP includes additional
margin such that it is more conservative than the LTSP. In Section 4.2.5 of TR defines the AFT
and ALT as double sided bands around the NTSP. The applicant states that at a minimum the
AFT includes reference accuracy, drift, and ALT uncertainties. The ALT is based on accuracy
of the channel calibration. The staff finds that this approach is consistent with RG 1.105,
Revision 3 and ANSI/ISA-67.04.01-2000.
Based on the discussion, sample calculations, and figures presented in the TR, the staff
finds that the B&W setpoint methodology demonstrates that the correct relationships
between the SL, AL, AV, NTSP, LTSP, AFT, and ALT will be ensured, that the basis for
the trip setpoint is correct, and that the requirements of GDC 13 and 20 are met.
NRC RIS 2006-17 detailed a concern with verification of operability using only AV or a one-
sided approach during periodic testing (channel operational test, calibration test). To address
this concern the B&W mPowerTM setpoint methodology uses double-sided acceptance criteria
bands. Figure 5.1 (above) and Table 4.2 (below) of the TR describe how the operability of the
instrument loop is evaluated. Exceeding the AFT in either the high or low direction may indicate
degraded performance and inability of the instrument channel to meet its intended function.
Another concern detailed in RIS 2006-17 is that 10 CFR 50.36(c)(1)(ii)(A) includes requirements
for a general class of LSSSs related to variables having significant safety functions but which do
not protect SLs. All operating plant licenses have TSs for LSSSs that are not related to SLs.
For these LSSSs, 10 CFR 50.36(c)(1)(ii)(A) requires that a licensee take appropriate action if it
is determined that the automatic safety system does not function as required. To address this
concern the B&W mPowerTm setpoint methodology uses double-sided acceptance criteria
bands. For this reason, the staff finds that the B&W setpoint methodology addresses the
concerns noted in RIS 2006-17 and is consistent with the requirements of 10 CFR 50.36.
-7-
Table 4.2: Instrument Operability During Periodic Surveillance Testing
As-found NTSP During Status of Channel Operability
Surveillance Testing and Required Actions
As-found NTSP within ALT (Region A Channel is operable, no action required. The results
of Figure 5.1) are tracked by plant procedures for historical trending.
As-found NTSP outside of ALT band, Channel is operable, recalibration is necessary to
but within AFT band (Region B of restore the NTSP within the ALT.
Figure 5.1)
Increasing process:
As-found NTSP is conservative with
respect to the AV (NTSP < AV) but
outside AFT band (Region D of
Figure 5.1); or Channel is inoperable. Recalibration is necessary to
restore the NTSP within the ALT, and evaluation of
Decreasing process: channel functionality is :required.
As-found NTSP is conservative
with respect to the AV (NTSP > AV)
but outside AFT band.
Channel is inoperable. Recalibration is necessary to
As-found NTSP-non-conservative to restore NTSP within the ALT, and evaluation of
the AV (Region C of Figure 5.1) channel functionality is required to return channel to
an operable status.
The B&W setpoint methodology allows for a minimum set of assumptions to be used (refer to
Section 3.5 of the TR). This minimum set of assumptions will yield conservative uncertainties
used in the calculations and less chance of error during calibration of instrument channels,
which the staff finds reasonable and acceptable. Following the setpoint calculation flow
depicted in Figure 4.1of the TR, the pertinent information required to be documented for each
calculation is collected in a typical data sheet as shown in Table 4.1 of the TR. This table also
provides traceability and documentation of the loop data and uncertainties used. The results of
the calculation are documented in accordance with controlled plant procedures and programs
(such as the Setpoint Control Program) with adequate detail so that all bases, equations, and
conclusions are fully understood and documented. Table 4.1 of the TR includes a list of
uncertainties that must be considered for inclusion in the total channel uncertainty (CU)
calculation.
The surveillance and calibration intervals are determined as part of the development of the
reference technical specifications. Determination of surveillance and calibration intervals takes
into account the ,uncertainty due to instrument drift as described in this report such that there is
reasonable assurance that the plant protection system instrumentation is functioning as
expected between the surveillance intervals. Plant-specific procedures will include required
methods to evaluate the historical performance of the drift for each instrument channel and
confirm that the surveillance and calibration intervals do not exceed the assumptions in the plant
safety analysis. The guidance contained in GL 91-04 is used to evaluate and determine the
-8-
R0003-08-002089-A Page 13 of 1.13 January 2013, Revision 3
acceptable surveillance and calibration intervals for each instrument channel as needed. For
these reasons the staff finds that the B&W setpoint methodology conforms to ANSI/ISA-
67.04.01-2000 and RG 1.105, Revision 3 with respect to assumptions and data used to
determine the uncertainties and select the trip setpoint.
The B&W setpoint methodology combines the uncertainty of the instrument loop components to
determine the CU for the functions of the reactor protection system and other important
instrument setpoints. All appropriate and applicable uncertainties are considered for'each
reactor protection system and other important instrument setpoint functions. Section 4.1:.3.1 of
the TR lists elements of uncertainty that are considered typical, but not inclusive, and the list is
consistent with ANSI/ISA-67.04.01-2000. Other considerations that contribute to the
uncertainty, such. as environmental conditions and installation details of the components are
also factored into the CU. For these reasons, the staff finds',that the B&W setpoint methodology
conforms to ANSI/ISA-67.04.01-2000 and RG 1.105, Revision 3 withrespect'to uncertainty
terms, bias values, and correction factors used to select the trip setpoint.
The CU values are established at a 95 percent probability and a 95 percent confidence level,
using a 2 sigma Gaussian distribution which is consistent with RG 1.105, Revision 3. The CU
calculation is based on the following:
I. Random, independent uncertainties are eligible for the square-root-sum-of-
squares method (SRSS) combination propagated fromthe process
measurement module through the signal conditioning module of the instrument.
channel to the device that initiates the actuation. Refer to Sections 3.3 and
3.3.1 of the TR.
I1. Dependenfuncertaintiesare combined algebraically to create a larger,
independent uncertainty that is eligible for SRSS combination. Refer to Section-
3.3.2 of the TR.
Ill. Non-random, bias and abnormally distributed uncertainties are those that
consistently have the same algebraic sign., If they are predictable for a given
set of conditions because of a known positive or negative direction, they are
classified :as bias with a known sign. If they do not have a known sign, they are
treated conservatively by algebraically adding the bias to-the CU of interest
(negative bias for increasing setpoints and positive bias for decreasing
setpoint)'as shown in the equations in Sections 4.2.2 and 4.2.3 of the TR.
These are classified as bias With an unknown sign'. Refer to Sections 3.4.1 and
3.4.2 of the TR.
The staff finds 'that the described method of statistical' combination of uncertainties conforms to
ANSIiSA-67.04.01-2000 and to RG 1.105, Revision 3.
The equations for determining module and channel uncertainty; and trip setpoint shown in
Sections 4.2.1, 4.2.2, and 4.2.3 conform to ANSI/ISA-67.04.01-2000 and to RG 1.105, Revision
3.
-9-
R0003-08-002089-A Paae 14 of 113' January 2013. Revision 3
. . . . I . . . . . . . .
All NRC RAIs and acceptance review comments have been resolved (References 2 through 7)
and incorporated into TR R0003-08-002089, Revision 3. There are no RAI open items.
Based on the discussion above, the staff finds that TR R0003-08-002089, Revision 3 follows the
guidance of RG 1.105, Revision 3, RIS 2006-17, GL 94-01, and ANSI/ISA-67.04.01-2000 with
respect to setpoint methodology and therefore complies with the NRC regulations for ensuring
that setpoints for safety-related instruments are initially within and remain within the technical
specification limits.
5.0 CONCLUSION
The staff has reviewed the B&W mPowerTM Instrument Setpoint Methodology Topical Report
(Reference 7) and found that (1) the setpoint calculation methods are adequate to assure that
protective actions are initiated before the associated plant process parameters exceed their
analytical limits, (2) the setpoint calculation methods are adequate to assure that control and
monitoring setpoints are consistent with their requirements, and (3) the established calibration
intervals and methods are consistent with safety analysis assumptions. Therefore, the staff
concludes that the proposed TR R0003-08-002089, Revision 3, is an acceptable setpoint
methodology that satisfies the requirements of 10 CFR Part 50, Appendix A, GDC 13 and 20, of
10 CFR Part 50, Appendix B, Criterion Xl, of 10 CFR 50.36(c)(1)(ii)(A) and 10 CFR 50.36 (c)(3),
and of 10 CFR 50.55a(h), which requires compliance with IEEE Std. 603-1991.
If this TR is referenced in a design certification application under 10 CFR Part 52, the
application must include ITAAC for the plant-specific setpoint analysis, which details the
procedures for establishing the setpoints including the margins and their location. Prior to initial
fuel load, a reconciliation of the setpoint analysis and setpoint program against the final design
for each plant must be performed, as required by the ITAAC. The staff will review the proposed
ITAAC during the design certification review.
6.0 REFERENCES
1. B&W letter BW-JAH-2010-230, dated October 28, 2010, (ML103020473) B&W submitted,
for U.S. Nuclear Regulatory Commission (NRC) staff review, TR 08-002089, Revision 0,
"Instrument Setpoint Methodology."
2. NRC Request for the Review of Babcock & Wilcox Company TR 08-002089-000, Revision
0, "Instrument Setpoint Methodology, October 2010," dated April 7, 201.1 (ML1 10900508).
3. B&W letter BW-JAH-2011-253, dated June 30, 2011, (ML1 1 182C034) B&W submitted, for
U.S. Nuclear Regulatory Commission (NRC) staff review, TR 08-002089, Revision 1,
"Instrument Setpoint Methodology" (ML1 1182C035).
4. NRC Acceptance for Review of Babcock & Wilcox Company TR 08-002089-001', Revision 1,
"Instrument Setpoint Methodology Topical Report," dated August 24, 2011 (ML1 12351116).
5. Request for Additional Information 6236 RAI Letter No. 4, dated December, 22, 2011, for the
review of B&W mPower Reactor Project Instrument Setpoint Methodology Topical Report
08-002089 Revision 1 (ML1 1357A141).
-10-
R0003-08-002089-A Page 15 of 113
6. B&W letter BW-JAH-2012-277, dated February 2, 2012, "Babcock & Wilcox Nuclear Energy,
Inc. (B&W NE) Response to NRC Request for Additional Information" (ML12037A001)
7. B&W letter MPWR-LTR-12-00051, dated May 21, 2012, (ML12143A424) B&W submitted,
for NRC staff review, TR R0003-08-002089, Revision 3, "Instrument Setpoint Methodology"
(ML12153A304).
8. ANSI/ISA--67.04.01-2000, "Setpoints for Nuclear Safety-Related Instrumentation," February
2000 (Equivalent to ANSI/ISA-S67.04-1994, Part 1).
-11-
R0003-08-002089-A
Page 16 of 113
Section B
R0003-08-002089-A Page 17 of113. January 2013, Revision 3,
BI6W
babcock. & wilcox nuclear energy
b 109 rams.ey place. lynchburg, va 24501 , p honne 434.316.7592.
I tax 434.3,16.7534 0 www~babcock.comn
Octobe" 286, 2010
BWrJAH-2010-230.
U.S. Nuclear Regulatolry Commission
One White Flint North
11555 Rockville Pike.
Rockville, MD020852-2738
Babcock & Wilcox Nuclear Energy, Inc.
Dodcket Number-PROJ0.776
Project Number-776
Subject: Submittal of Babcock & Wilcox Nuclear Energy, Inc. (B&W NE)lInstrduhent.Setpoint
Methodology Topical Report (Report Number 08-002089-000)
Inaccordance with the B&WNE schedule for submittal of tichnical and topical reports as, updated,
on July-22, 2010, we are providing the above referenced topical report foe'NRC review. This report
is non-proprietary.
Questions ohcernring this submittal may be, directed to Jeff Halfinger at 434-316-7507 (email:
jahalfinper(babcock.com) or T. J. Kim at.434-382-9791 (email: tikimCbabcock.com).
ey
.
a
lf i
g
r
', Technology evelopment
WNE
yW
4
:Robedt E. McLft'hlin
Director, QualityAssurance
B&WNE.
T.J Ki'm
Licensing Director
B&W NE,
JHA/jlr
cc: Joelle L. Starefos,. NRC, TWFN 9-F-27
:Stewart L. Magruder,. Jr., NRC; TWFN:9-F-27
babcock & wilcox nuclear energy, Inc.. a McDermott company
/.
R0003-08-002089-A Page 18 of113
Section C
R0003-08-002089-A
Page 19 of113
B .w babcock& wilcox nuclear energy_
P 109 ramsey place I1 lynchburg, va 24501 e phone,434.316.75 92
oP fax 434-316.7534 b www.babcock.corn
June 30, 2011 BW-JAH-2011-253
Docket Number-PROJ0776
Project Number-776
Subject: Submittal of Babcock & Wilcox Nuclear Energy Inc. (B&W NE) Instrument Setpoint
Methodology Topical Report Revision 1 (Report Number,08-002089-001)
On October 28, 2010, B&W NE submitted to NRC Revision 0 of the above referenced topical report
for technical staff review as part of our pre-application effort. Enclosed is Revision 11 of the
referenced report for review. We have revised the report based on, preliminary feedback from the
NRC staff. Accordingly; limited portions of this report have been modified to:
1. clarify Section 4.2.1 of the report to describe the mathematical relationship between the
nominal trip set point (NTSP) and the limiting trip set point (LTSP),
2. clarify the definition 'of margin,
3. add to the report a typical calculation (not design-specific) showing the determination. of
uncertainties, and application of the setpoint methodology for a typical instrument channel
with resulting sample results for the analytical limit (AL), the channel uncertainty (CU), LTSP,
NTSP, and the allowable value (AV),
4. remove references to use of a "graded approach",
5. clarify the relationships between design and safety analysis methods and methods applied
during surveillance and calibration (Figure 5.1),
6. clarify that as-found tolerance is derived from the NTSP to establish the allowable
value,(Figure 5.1), and
7. clarify that the allowable value is the limiting safety system setting (LSSS) in Figure 5.1.
Questions concerning this submittal may be directed to Jeff Halfinger at 434-316-7507 (email:
ah Ifin e babcock.com) or T. J. Kim at 434-382-9791 (email: tmkimObabcock.com).
P', Technology De opment
&W NE
JAH/jlr
babcock & wilcox nuclear energy, inc., a Babcock & Wilcox company
Enclosure:
Methodology
Babcock & Wilcox Nuclear Energy Inc. (B&W NE) Instrument Setpoint
Topical Report Revision 1 (Report Number 08-002089-001)
' R0003-08-002089-A
Section D
R0003-08-002089-A Page'22 of 113
Mazza, Jan
From:
Sent:
To:
Cc:
Attachments:
Mazza, Jan
Thursday, December 22, 2011 4:51 PM
'jahalfinger@babcock.com'; 'pshastings@generationmpower.com'; 'Poslusny, Chester'
Starefos, Joelle; Ashcraft, Joseph; Jung, Ian; Magruder, Stewart
Request for Additional Information 6236 RAI Letter No. 4.pdf
December 22, 2011
SUBJECT: REQUEST FOR ADDITIONAL INFORMATION LETTER NO. 4 FOR THE REVIEW OF BABCOCK
& WILCOX (B&W) mPOWER REACTOR PROJECT INSTRUMENT SETPOINT METHODOLOGy
TOPICAL REPORT 08-002-2089 REVISION 1 (TAC NO. RN6113)
Dear Mr. Halfinger:
By letter dated June 30, 2011, (ML11182C034) B&W submitted, for U.S. Nuclear Regulatory Commission (NRC) staff
review, Topical Report (TR) 08-0022089, Revision 1, "Instrument Setpoint Methodology" (ML11 182C035). The
NRC staff is performing a detailed review of this topical report to enable the staff to reach a conclusion on the
safety of the proposed application. The NRC staff has identified that additional information is needed to
continue portions of the review. The staff's request for additional information (RAI) is contained in the
enclosure to this email.
Consistent with the NRC letter dated, August 24, 2011 (ML1 12351116), to support the review schedule, you are
requested to respond by February 2, 2012. If changes are needed to the topical report, the staff requests that
a revision to TR 08-002-2089, "Instrument Setpoint Methodology," be submitted with the RAI responses.
If you have any questions or comments concerning this matter, you may contact me at 301-415-6091.
Sincerely,
/RA/
Jan Mazza, Project Manager
Projects Branch
Division of Advanced Reactors and Rulemaking
Office of New Reactors
Docket No. PROJO776
eRAI Tracking No. 6236
Email Attachment: Request for Additional Information 6236 RAI Letter No. 4
OFFICE NRO/DE/ICE NRO/DE/ICE NRO/DARR/APRB I NRO/DARR/APRB
NAME *JAshcraft *IJunge *JMazza JStarefos
DATE 12/2112011 12/21/2011 I 12/22/2011 12/22/2011
*Approval captured electronically in the electronic RAI system.
Jan Mazza
I
R0003-08-002089-A Page 23 of 113
NRC obli of e
301-41540498
Jan.Mazzatnnrc.gov
Request for Additional Information No. 6236
RAI Letter No. 4
12/22/2011
mPower Pre-Application Activities
Babcock and Wilcox
Docket No. PROJ 0776
SRP Section: 07.01-C Appendix - Guidance for Evaluation of Conformance to IEEE Std. 603
Application: Topical Report 08-002089 Instrument Setpoint Methodology
Acceptance Criteria: IEEE Std. 603 1991, Clause 6.8, RG 1.105-Rev.3, ISA-67.04-1994, Part I
Technical Branch: Instrumentation and Controls Branch (ICB)
07.01-C Appendix-1
Section 3.1 - On page 3, paragraph 6 states, "Recognizing that RG 1.105, Revision 3,
was published in 1999, the B&W mPower instrument setpoint methodology follows the
guidance provided by ANSI/ISAS67.04.01-2000 (Ref. 6.3.1), which is equivalent to
ANSI/ISA S67.04-1994, Part I (now ANSI/ISAS67.04.01-2006)."
What is meant by "(now ANSI/ISAS67.04.01-2006)?" It is listed as reference 6.3.3,
however, other than this statement, it is not mentioned anywhere else. Clarify whether
the mPower setpoint methodology conforms to RG 1.105 Rev. 3 which endorses,
ANSI/ISA S67.04-1994. If the setpoint methodology does not meet RG 1.105 Rev. 3
then demonstrate how the methodology meets the Regulations.
07.01-C Appendix-2
Section 3.3.2 - Regarding the last sentence of 3.3.2, the staff requests the applicant to
clarify whether after the uncertainties are algebraically summed, the SRSS would then
be applied as discussed in the second paragraph of 4.1.4.
07.01-C Appendix-3
Section 3.5 - The first bullet in this section appears to conflict with Section 3.4.1 (both
stated below). The staff requests the applicant explain this inconsistency.
3.4.1 Any bias effects that cannot be calibrated out are directly accounted for in the uncertainty
calculation.
3.5 Where bias terms have opposite effects on instrument accuracy (positive versus negative), and are
both of known magnitude, the two uncertainties may be used to offset each other.
07.01-C Appendix-4
Section 3.5 - In the paragraph titled, Assumptions, clarify the assumption for instrument
calibration (last bullet) is valid for sensor locations that may be exposed to the
environment during calibration.
R0003-08-002089-A Page 25 of-.113
07.01-C Appendix-5
Figure 4.1 - The setpoint steps at the bottom of the figure (below the step "Determine
the Setpoint and Allowable Value"), deviate from ANSI/ISA 67.04.02 Figure 2. Explain
how this meets the guidance in RG 1.105 Rev 3.
07.01-C Appendix-6
Section 4.1.3.1 - The last paragraph in this section lists the "elements of uncertainty for
any module" and further specifies the definitions are provided in Appendix B. Two of the
elements the "as-left tolerance specification" and "as-found specification" are not defined
in Appendix B. The staff requests the applicant clarify the definitions of these elements.
07.01-C Appendix-7
Section 4.1.5 - The staff requests the applicant specify which equation applies to "Trip
SetPoint".
07.01-C Appendix-8
Section 4.1.6 - The last half of the second paragraph states "A setpoint found within the
allowable value region, but outside the as-found tolerance, is considered operable, but
degraded. It is acceptable with respect to the analytical limit; however, the instrument
must be reset to return it within the allowed as-left tolerance region (see definitions)..."
This appears to conflict with Section 4.2.5 which states "The AFT is included to
determine if the instrument needs to be reset after calibration or, if outside of the
tolerance, requires further investigation as to its operability. The as-found readings also
provide data for establishing actual instrument drift." The staff requests that the applicant
explain this apparent contradiction and/or to revise Section 4.1.6 or Section 4.2.5 to
eliminate the conflict.
In addition, providing an explanation for the following four scenarios listed in the mPower
Setpoint Methodology Topical Report in terms of calibration requirements, instrument
operability, and channel operability is optional but would aid in additional clarification for
the section.
" As-found is within as-lefttolerance
" As-found is outside as-left tolerance but within as-found tolerance
As-found is outside as-found tolerance but within AV
" As-found is above/below AV
07.01-C Append ix-9
Figure 5.1 - This figure shows Margin (Note 2) added to the setpoint calculation.
The staff requests that the applicant clarify the use of margin in the figure and revise the
figure to reflect both the +/- of AFT, ALT, and the location of Margin (Note 2) in
relationship to NTSP, AFT and AV (see below).
2
R0003-08-002089-A
Sections 4.2.4, 4.2.5 and Figure 6.1:
* Section 4.2.4 - How is AFTTOT calculated as a +/- value and shown on both
sides of NTSP on Figure 5.1?
, Section 4.2.5 - How is AFTn calculated as a +/- value?
* Section 4.2.4 - Explain why the definition of Margin is different from Note 2
on Figure 5.1.
e Is Margin (Note 2) correctly shown on Figure 5.1? see bullet 1 above.
e What value of ALT would be used in Figure 5.1? (Refer to RG 1.105 Rev. 3
Figure 1, "E. Region of Calibration Tolerance")
07.01-C Appendix-10
Section 4.2.5 - The staff requests the applicant to explain how the mPower Setpoint
Methodology conforms to BTP 7-12 or the corresponding regulations with regards to:
" Use of as found and as left data (sensors, SPs)
" How are AV, as-found and as-left values verified for a SP that is within a digital
platform?
07.01-C Appendix-1 1
Appendix A Figure A.2 - The staff requests the applicant to respond to the following:
# Is margin correctly shown as 5.5 psig?
* Using example problem and Notes 1& 2 from Figure 5.1, what would AV,
Margin 2 and AFT TOTbe if Margin 1 is 5.5 psig (allowed by note 1) versus
55 psig?
07.01-C Appendix-12
* Using AFTTOT +/- 15.1 psig (-15.1 psig), what would be the operating
margin (OM) as described in Section 4.2.6 in order to avoid potential
spurious channel trips?
* Is the methodology described in 4.2.6 sufficient for all cases?
07.01-C Appendix-13
Figure 4.1 - The portion of the figure that shows the setpoint calculation for a harsh
environment does not specify seismic effects as described in section 4.3.1.1 paragraph
2 and equation 4:2.1. Is seismic considered in figure 4.1 and if so how would this be
3
R0003-08-002089-A Page 27 of 113'
applied to the setpoint calculation for normal, seismic, and other postulated accident
conditions, as applicable?
4
R0003-08-002089-A
Section E
R0003-08-002089-A
Page 29 of 113
January2013, Revision 3
B w babcock & wilcox nuclear energy
P 109 ramsey place b lynchburg. va 2450 1 P phone 434,316,7592
o fax 434.316 7534 b www,babcock.com
February 2, 2012 BW-JAH-2012-277
Project Number-776
Subject: Babcock & Wilcox Nuclear Energy, Inc. (B&W NE) Response to NRC Request for
Additional Information
Reference: 1. B&W NE Instrument Setpoint Methodology Topical Report 08-002089-001
2. Request for Additional Information Letter No.4 for the Review of Babcock & Wilcox
(B&W) mPower Reactor Project Instrument Setpoint Methodology Topical Report
08-002-2089 [sic] Revision 1
On October 28,-2010, B&W NE submitted to the NRC Revision 0 of the above referenced topical
report for technical staff review as part of our pre-application effort. Subsequently, on
June 30, 2011; as a result of preliminary feedback from the NRC staff, B&W submitted Revision 1
to the Report (Ref, 1).
On December 22,.2011, the NRC issued a Request for Additional Information (RAI) (Ref 2)
containing thirteen (13) questions and a request that the responses to the questions and a revision
to the Instrument Setpoint Methodology Topical Report, if needed, be submitted by
February 2, 2012.
Enclosed is the set of B&W's responses to the RAI's questions which include proposed clarification
to information provided in the topical report, and where appropriate, revised text, tables or figures to
be incorporated into Revision 2 to B&W's Instrument Setpoint Methodology Topical Report 08-
002089, pending satisfactory resolution of this RAI.
Questions concerning this submittal may be directed to Jeff Halfinger at 434-326-7507 (email;
iahalfinertbabcockcom) or T.J. Kim at 434-382-9791 (email: tikimr,,babcock.com).
echnologygeve p ment
babcock &"wilcox nuclear energy, inc., a Babcock & Wilcox compainy
R0003-08-002089-A. Page 30 of 113 January 2013, Revision 3
JAH/jlr
Attachment: Setpqint Methodology Topical Report RAI Responses
R0003-08-002089-A
Page 31 of 113
RAI No. 6236 Ltr. No. 4
Docket No. PROJ 0776.
Babcock & Wilcox Nuclear Energy, Inc. Response to
Requests for Additional Information No. 6236
RAI Letter No. 4
B&W mPower Pre-Application Activities'
Topical Report 08-002089-001
Question 07.01-C Appendix-1
Section 3.1 - On page 3, paragraph 6 states, "Recognizing that RG 1.105, Revision 3, was
published in 1999, the B& W mPower instrument setpoint methodology follows the guidance
provided by ANSI/ISAS67.04.01-2000 (Ref 6.3.1), which is equivalent to ANSI/ISA S67.04-
1994, Part I (now ANSI/ISAS67.04.01-2006)."
What is meant by "(now ANSI/ISAS67.04.01-2006)?" It is listed as reference 6.3.3, however,
other than this statement, it is not mentioned anywhere else. Clarify whether the mPower.
setpoint methodology conforms to RG 1.105 Rev. 3 which endorses ANSI/ISA S67.04-1994. If
the setpoint methodology does not meet RG .1.105 Rev. 3 then demonstrate how the
methodology meets the Regulations.
B&W NE Response
The intent of the cited reference was to demonstrate that the B&W Instrument Setpoint
Methodology follows the guidance provided by ANSI/ISA $67.04.01-2000, which is equivalent
to ISA-67.04-1994, Part I. The current version of this standard was issued as ANSI/ISA
67.04.01-2006.
The statement was intended to make note of the fact that since the issuance of ISA S67.04-
1994 Part I, which is endorsed byRG 1.105, Revision 3, updated versions of the applicable
standards have been issued. By incorporating the latest industry guidance contained in
ANS I/ISA 67.04.01-2000 and ANSI/ISA 67.04.01-2006, the B&W InstrumentSetpoint
methodology also ensures that RG 1.105; Revision 3, and the issues identified in RIS 2006-17
are also addressed.
The reference to ANSI/ISAS67.04.01-2006 will be deleted (Ref. 6.3.3), and Section 3.1,:
paragraph 6 (page 3) will be revised as follows:
The calculation of safety-related instrument setpoints for the B&W mPower reactor is based on
RG 1.105, which describes a method acceptable to the NRC for complying with the applicable
regulations. RG 1.105 endorses the use of ISA-67.04-1994, Part I. Recognizing that RG 1.105,
Revision 3, was published in 1999, and to ensure the issues identified in RIS 2006-17 (Ref.
6.2.4) are addressed, the B&W mPower instrument setpoint methodology follows the guidance
provided by ANSI/ISA-S67.04.01-2000 (Ref. 6.3.1), which is equivalent to ISA 67.04-1994, Part
I and ANSI/ISA-RP67.04.02-2000.
Page 1 of 20
R0003-08-002089-A
Page 32 of 113
Docket' No. PROJ 0776
Section 3.3.2 - Regarding the last sentence of 3.3.2, the staff requests the applicant to clarify
whether after the uncertainties are algebraically summed, the SRSS would then be applied as
discussed in the second paragraph of 4.1.4.
B&W NE Response
Section 3.3.2 contains information for the treatment of random uncertainties that are not
independent (i.e., dependent uncertainties). In treating dependent uncertainties, the
methodology conservatively combines these random, dependent uncertainties algebraically
into a larger, more conservative independent uncertainty term which can then be combined
using the SRSS method. This is consistent with the guidance presented in ISA-RP67.04.02-
2000.Section 3.3.2 and 4.1.4 will be revised to clarify the treatment of dependent uncertainties.
A sentence will be added to the end of section 3.3.2 (pages 4-5) as shown with changes as
highlighted in shaded text:
3.3.2 Dependent Uncertainties
Complicated relationships may exist between instrument channels and various instrument
uncertainties. As such, a dependency might exist between some random uncertainty terms and
parameters of an overall uncertainty analysis. A common root cause may exist which influences
other uncertainty, terms in the analysis with a known relationship. When these uncertainties are
included, they are added algebraically, which results in a statistically larger value for that
parameter when evaluated in the overall channel uncertainty. MT1 - 5e
palalati,
A sentence will be added to section 4.1.4, paragraph 2 (page 14) as shown below in shaded
text:
4.1.4 Channel Uncertainty
Individual module uncertainties and other uncertainty terms are combined to determine the
overall channel uncertainty (CU) using the equations shown in Sections 4.2.1 and 4.2.2
respectively.
As described earlier, the methodology used in this report to combine instrument loop.
uncertainties is an appropriate combination of those groups that are statistically and functionally
independent.
a 2
IlTel-asal F el a] a5 e flaen fi ee E s i t~~lp 6at ane l r!lS Temfjin Ia tfi-e~
Page 2 of 20
R0003-08-002086-A
Section 3.5 - The first bullet in this section appears to conflict with, Section 3.4. 1 (both stated
below). The staff requests the applicant explain this inconsistency.
3.4.1 Any bias effects that cannot be calibrated out are directly accounted for in the
uncertainty calculation.
3.5 Where bias terms have opposite effects on instrument accuracy (positive versus
negative), and are both of known magnitude, the two uncertainties may be used to
offset each other.
B&W NE Response
B&W agrees with NRC's comment above.
For cases where the bias terms are known with respect to sign and magnitude, the bias effect
can be accounted for directly in the instrument calibration procedure. The, intent of the
methodology was that in these cases, the bias term does not need to be included in the
uncertainty calculation.
Therefore, the topical report will be revised to delete the first sentence of the first bullet of
section 3.5 (page 5) and reads as follows:
If both magnitude and direction of a bias are known (e.g., transmitter static pressure span
effects), this effect can be accounted for in the instrument channel calibration procedure and
calibrated out of an instrument and thus eliminated from the uncertainty calculation.
Page 3 of 20
R0003-08-002089-A
Section 3.5 - In the paragraph titled, Assumptions, clarify the assumption for instrument
calibration (last bullet) is valid for sensor locations that may be exposed to the environment
during calibration.
B&W NE Response
To clarify how the temperatures of the instrumentation equipment are accounted for during
calibration, the last bullet of section 3.5 (page 6) will be revised as shown below in shaded text:
basedon theambient oenditions in ich =the instrumentation compoents are expected to
d ie i ant lIi aOlieurB The tem peatf
ipnl.sTetrmumentation accounts "fr p b ie between te raus associateadwtte
intrmet aibratfivoni a~nd"7 th amben codtoso=h ntle e~petadi ae the
~~~perature te deiain betee this assudcailibration tAemprtr n h aiu n
mi un amienttemeatueo h fclcto of th acua =11-6instrumnato The normal
temperature effects are accounted for as shown in the equations in Section 4.2.1. By using the
actual vendor data (typically stated in terms of + X % span per Y TF), actual calibration
temperatures and plant operating temperatures, the overall temperature effect is determined
and accounted for in the TE term for the specific instrument channel of interest, consistent with
the guidance contained in ANSI/ISA-RP67.04.02-2000 (Ref. 6.3.2).
Page 4 of 20
R0003-08-002089-A
Docket No. PROJ0776
Figure 4.1 - The setpoint steps at the bottom of the figure (below the step "Determine the
Setpoint and Allowable Value'), deviate from ANSI/ISA 67.04.02 Figure 2. Explain how this
meets the guidance in RG 1.105 Rev 3.
B&W NE Response
Figure 4.1 of the B&W Instrument Setpoint Methodology is similar to Figure 2 in ANSI/ISA
67.04.02-2000, slightly amplified to provide more prescriptive guidance for obtaining the trip
setpoint (NTSP).from the analytical limit (AL) based upon either an increasing or decreasing
direction of the process variable. The amplified portion of Figure 4.1 refers to section 4.2.3 for
the mathematical equation to use for calculating of the trip setpoint and provides guidance on
the use of the equations based upon the direction of the process variable.
The equation in section 4.2.3 for calculating the trip setpoint (NTSP) and limiting trip setpoint
(LTSP) is shown below in its current form:
LTSP = AL + CU
NTSP = AL + (CU + Margin)
Therefore, when following the guidance illustrated in Figure 4.1, and applying the mathematical
expressions from equation 4.2.3, for cases where the process signal increases towards the
analytical limit, NTSP and LTSP calculated as follows:
LTSP = AL - CU (increasing process)
NTSP = AL - (CU + Margin) (increasing process)
For cases where the process signal, increases towards the analytical limit, NTSP and LTSP
calculated as follows:
LTSP = AL + CU (decreasing process)
NTSP = AL + (CU + Margin) (decreasing process)
To summarize these steps, for an increasing process the channel uncertainty (CU) is
subtracted from the AL to obtain the LTSP, and the CU plus margin (if any) is subtracted from
the AL to obtain the NTSP. For a decreasing process, the CU is added to the AL to obtain the
LTSP, and the CU plus margin (if any) is added to the AL to obtain the NTSP. This is
consistent with and identical to the methods described in section 7.2 of ISA/ANSI-67.04.02-
2000.
These methods are consistent with the guidance in RG 1.105 for establishment of the LTSP as
the LSSS. The LTSP is determined by subtracting the CU from the AL for an increasing,
process, and adding the CU to the AL for a decreasing process. To determine the NTSP, a
value for safety margin may be added to the CU to add conservatism when establishingthe
trip setpoint. The CU is determined using accepted statistical methods. The AV is determined
as the limiting value that the NTSP may have when tested periodically and ensure that both
the AL and the SL are protected.
Page 5 of 20
R0003-08-002089-A
No changes to Figure 4.1 will be made; however, equation 4.2.3 (page 18) of the topical report
will be slightly modified to more clearly show this mathematical relationship with changes as
highlighted in shaded text:
4.2.3 Trip Setpoint
Page 6 of 20
Section 4.1.3.1 - The last paragraph in this section lists the "elements of uncertainty for any
module" and further specifies the definitions are provided in Appendix B. Two of the elements
the "as-left tolerance specification" and "as-found specification" are not defined in Appendix B.
The staff requests the applicant clarify the definitions of these elements.
B&W NE Response
The list in section 4.1.3.1 lists the various elements of uncertainty for a module. The terms
"as-left tolerance specification" and "as-found specification" should have matched the terms
defined in Appendix B. B&W recognizes that the identified names for the terms in our report
did not exactly match information included in Appendix B. Therefore, the list in paragraph 5 of
section 4.1.3.1 (pages 13-14) will be revised to exactly match the defined terms provided in
Appendix B as shown with changes highlighted in shaded text below.
Elements of uncertainty for any module that are considered are listed below (not all of the
uncertainties listed apply to every measurement channel). Definitions, as appropriate, are provided
in Appendix B.
" process measurements effect
" primary element accuracy
* drift
* temperature effects
* radiation effects
* static and ambient pressure effects
* overpressure effect
* measuring and test equipment uncertainty
* power supply effects
* indicator reading uncertainty
* conversion accuracy
0 seismic effects
0 environmental effects - accident
* as-found toleranee
* propagation of uncertainty through modules
Page"7 of 20
R0003-08-002089-A
Section 4.1.5 - The staff requests the applicant specify which equation applies to "Trip
SetPoint."
B&W NE Response
B&W will revise the Instrument Setpoint Methodology topical report to explicitly identify the
equations for the terms described in section 4.1.5. The following sentence will be added to the
beginning of section 4.1.5 (page 14) as listed below:
4.1.5 Trip Setpoint
The nominal trip setpoint (NTSP) and limiting trip setpoint (LTSP) are calculated using equation
4.2.3.
Page 8 of 20
R0003-08-002089-A Page 39 5f 113
Section 4.1.6 - The last half of the second paragraph states "A setpoint found within the
allowable value region, but outside the as-found tolerance, is considered operable, but
degraded. It is acceptable with respect to the analytical limit; however, the instrument must be
reset to return it within the allowed as-left tolerance region'(see definitions)..."
This appears to conflict with Section 4.2.5 which states "The AFT is included to determine if
the instrument needs to be reset after calibration or, if outside of the tolerance, requires further
investigation as to its operability. The as-found readings. also provide data for establishing
actual instrument drift." The staff requests that the applicant explain this apparent contradiction
and/or to revise Section 4.1.6 or Section 4.2.5 to eliminate the conflict.
In addition, providing an explanation for the following four scenarios listed in the mPower
Setpoint Methodology Topical Report in terms of calibration requirements, instrument
operability, and channel operability is optional but would aid in additional clarification for the
section.
- As-found is within as-left tolerance
- As-found is outside as-left tolerance but within as-found tolerance
- As-found is outside as-found tolerance but within AV
- As-found is above/below A V
B&W NE Response
To more clearly demonstrate the conditions during periodic surveillance testing that could
occur, and the status of-channel operability during periodic surveillance testing, the following
revisions to the topical report will be made.
Section 4.1.6 and 4.2.5 will be revised to clearly delineate the disposition of the as-
found conditions during periodic surveillance testing.
. Revisions to Figure 5.1 (see response to Question 07.01-C Appendix-9) will be made to
more clearly demonstrate the process of verifying channel function and operability
during testing.
The following text will be revised in paragraph 2 in section 4.1.6 (pages 115-16) with changes
highlighted in shaded text below:
The AV is a value that the trip setpoint might have when tested periodically and accounts for
instrument drift and other uncertainties applicable to normal plant operation associated with the
test during norma! plant operation including: instrument drift, reference accuracy, as-left
tolerance from the previous calibration and measurement and test equipment uncertainty. A
setpoint found within the allowable value region, but outside the as-found tolerance, is
considered operable, but degraded. It is acceptable with respect to:the analytical limit; however,
the instrument must be reset to return it within the allowed as-left tolerance region (see
definitions)._'A _ ifoundoutsidethe allowableve regions declared inoperable
and an evaiuation ofacceptable channel functionalityi efre.Tecanli eurdt
be albraedto etrn hesetoit wthn heacceptable tolerance range. Plant-specific
prcdrswl anan n rc h eut of the periodic sureillance test procedures and
the historicalas-found and aslft data obtined during sui-veillance testing. These data will be~
eautdto confirm the ass mptions for intuetcanldrft and Uncertainty data remnains
Page 9 of,20
R0003-08-002089-A Page 40 of 113
The changes to section 4.2.5 include revisions to the first paragraph and additional information
provided are shown below (pages 19-21) with changes highlighted in shaded text below:
Therefore:
AFTn = (RAn2 + DRn
2
+ ALTn
2
+ MTEn
2
)1/2
Where:
AFT = As-found tolerance (any typical module).
n = Module "n".
RA
=
Device
refe
DR = Device allo
ALT = As-left toler
rence accuracy.
wance for drift.
rance.
MTE = Measurement and test equipment effect.
The AFT is evaluated to determine if the instrument needs to be reset after calibration or, if
outside of the tolerance, requires further investigation as to its operability. The as-found
readings also provide data for establishing actual instrument drift. In accordance with RG 1.105
(Ref. 6.2.1) and BTP 7-12, plant specific procedures are required to track, trend and maintain
the results of periodic surveillance testing (i.e., the as-found and as-left values for sensors (as
applicable) and modules associated with the instrument loop) for proper management of
instrument uncertainties including drift.
Table 4.2 below, that will be added to the report, shows the various conditions to consider
during surveillance testing of the instrumentation channel and are consistent with RIS 2006-17
(Ref. 6.2.4).
Page 10 of 20
R0003-08-002089-A
Page 41 of 113
As-found NTSP within ALT (Region A of Channel is operable, no action required. The results are
Figure 5.1) tracked by plant procedures for historical trending.
As-found NTSP outside of ALT band, but Channel is operable, recalibration is necessary to restore
within AFT band (Region.B of Figure 5.1) the NTSP within the ALT.
Incr6asinq process:
outside AFT band (Region D of Figure
5.1); or
Recalibration is necessary to restore the NTSP within the
Decreasin r
ALT, and evaluation of channel functionality is required.
respect to the AV (NTSP > AV) but
outside AFT band.
Recalibration is necessary to restore NTSP within the ALT,
As-fRegiound NP non erve t) t and evaluation of channel functionality is required to return
AV (Region C of Figure 5.1 ) channel to an operable status.
Page 11 of 20
RAI No. 6236 Ltr. No. 4,
The staff requests that the applicant clarify the use of margin in the figure and revise the figure
to reflect both the +/- of AFT, ALT, and the location of Margin (Note 2) in relationship to NTSP,
AFT and A V (see below).
" Section 4.2.4 - How is AFTTOT calculated as a +/- value and shown on both
sides of NTSP on Figure 5.1 ?
" Section 4.2.5 - How is AFTn calculated as a +/- value?
" Section 4.2.4 - Explain why the definition of Margin is different from Note 2
on Figure 5.1.
" Is Margin (Note 2) correctly shown on Figure 5.1? see bullet I above.
" What value of ALT would be used in Figure 5.1? (Refer to RG 1.105 Rev. 3
B&W NE Response
To clarify the relationship between Margin and NTSP, AFT and AV a number of changes will
be made to Figure 5.1 and the text contained in Sections 4.2.4 and 4.2.5 of the topical report.
The as-found tolerance is used, when applied to the NTSP, to determine the allowable value
for the instrument channel. The AV is the limiting value of an instrument's as-found trip setting
during surveillance testing while still ensuring the AL and SL are protected. If the as-found
value for the NTSP is non-conservative with respect to the AV, actions are required to restore
the NTSP. Additionally, RIS 2006-17 raised concerns about conditions where the as-found
NTSP may be more conservative than the AV, indicating that abnormally large changes in the
trip setpoint have occurred which could be signs of the channel malfunctioning. Thus a concept
of a double-sided acceptance criteria band for the measured trip setpoint during surveillance
testing was introduced.
The determination of the AFTTOT in section 4.2.4 (page 19) has been revised by removing the
margin term in the determination of the AV, and includes the proper mathematical operator ()
to ensure the double-sided band is correctly applied as shown below with changes highlighted
in shaded text:
4.2.4 Allowable Value
AV = NTSP + AFTTOT
Where:
AV = Allowable value.
NTSP = Trip setpoint.
AFTTOT = Total as-found tolerance for the entire instrument channel.
Page 12 of 20
a~piedas dobl-sided banid around te NTSP.
AFTTOT determination includes consideration of all channel AFT uncertainties pertaining to the
calibration being performed. Therefore, When considering AV, AFTTOT is based on;
AFTTOT = (AFT
1
2
+AFT
2
2
+....+....+...+AFTn
2
)
11 2
Where:
AFT = as-found tolerance for module "n" (see 4.2.5).
Figure 5.1 will be updated to properly illustrate the application of a double-sided band for the
AFTTOT as applied to the NTSP to ensure consistency with revisions to equation 4.2.4
described above. Additional revisions and enhancements to Figure 5.1 (page 24) include the
following and the revised figure is shown below:
* Addition of a double-sided band for the ALT to aid in determination of channel
operability and be consistent with Figure 1 in RG. 1.105.
* Illustration of regions of different conditions that may exist during periodic surveillance
testing to clarify status of channel operability and required actions (if any).
* Removal of the margin applied to the AFTTOT and its associated note (Note 2). (To
protect against the potential for masking of equipment degradation during periodic
surveillance testing.)
Page 13 of 20
R0003-08-002089-A
Plant Safety Analysis and Desian Basis
SAFETY LIMIT (SL)
ANALYTIC
LIMIT
(AL) -
CHANNEL
UNCERTAINTY (CU)
[Equation 4.2.2]
LIMITING TRIP
SETPOINT (LTSP)
(Equation 4.2.3]
MARGIN
(NOTE 1)
TRIP SETPOINT (NTSP)
(Equation 4.2.3]
NORMAL
[Equation 4.2.6]
Periodic Surveillance Testina
[Equation 4.2.41
AS-LEFT I TOTAL AS-FOUND
-,-TOLERANCE > TOLERANCE BAND (AFTToT)
(ALT) [Equation 4.2.5]
NORMAL OPERATING
UPPER LIMIT (NUL)
OPERATING RANGE -
-i
i Recalibration is required and must be evaluated
M Recalibrathon is required and must be evaluated
SYSTEM SHUTDOWN
PROCESS PARAMETER
NOTES:
protection of the analytical limit.
Figure 5.1: Setpoint Relationships - For Increasing Setpoint (Similar for decreasing setpoint, but
process is decreasing towards the setpoint).
Page 14 of 20
R0003-08-002089-A
RAI No. 6236 Ltr. No.4
Section 4.2.5 - The staff requests the applicant to explain how the mPower Setpoint
Methodology conforms to BTP 7-12 or the corresponding regulations with regards to:
- Use of as found and as left data (sensors, SPs)
- How are AV, as-found and as-left values verified for a SP that is within a digital
platform?
B&W NE Response
The review guidelines contained in BTP 7-12 contain numerous acceptance criteria and review
procedures. Specifically, the review procedures contain guidance that the instrument setpoint
methodology should include the basis for determination of the as-found and acceptable as-left
bands and evaluation of the instrument operability based on acceptable as-found and
acceptable as-left bands. Additionally, the methodology should contain measures for tracking
and trending of historical as-found and as-left data to ensure each instrument channel exhibits
random drift characteristics, and confirmation that the uncertainty data remains valid.
The basis for the acceptable as-found and as-left bands and operability determination method
is presented in the B&W Instrument Setpoint Methodology. Please see the response to
Questions 07.01 -C Appendix-8 and 07.01-C Appendix-9 that addresses this question.
Plant-specific procedures will track the results of the periodic surveillance test procedures to
trend and evaluate the as-found and as-left data to evaluate the instrument channel drift and
uncertainty data. Section 4.2.5, paragraph 3 (page 20) and paragraph 5 (page 20) of the
topical report will be revised to include requirements for these steps as shown below.
The following sentences will be added to section 4.2.5, paragraph 3 (page 20) with changes
In accodance with , 1.1- (Ref. 62.1) ad BP 7-12, plan t specific prcduresaerequhire
totra'ck, trend-and m~aintain the results of periodic suiveillnce testin (i e.,.the as'-fou'nd and as-
left v'al~es for sensors, (as applicable) and modules associated wihtent-me* op o
proper managementof insrument uncertainties InClUd1jng drft
The following sentences will be added to section 4.2.5, paragraph 5.(page 20) as shown in
shaded text, below:
of th'rft fr each instrument channel and confirrn the surveillance and calibration intervas do
hot exce~d the assumptions in the p'lant safety analysis: Th~e guidan~ee contained in Generic
Letter 91-04r may be used to evaluate and determine the accptab le Surveillance arid calibraion
intervls for each istrum~ent channel.
In channels using digital processing equipment, uncertainties are introduced by analog-to-
digital (A/D) and digital-to-analog (D/A) conversions within the specific platform hardware.
These uncertainties are typically provided by the platform manufacturer or determined through
testing. Uncertainty data sources within the software are typically determined by the software
Page 15 of 20
)
designer and quantified. They can then be combined using the methods described in the
topical report.
With most digital platforms, they are self-calibrating and errors due to drift or temperature are
accounted. in the reference accuracy determined by the platform manufacturer. Thus, the only
applicable uncertainty is associated with the A/D conversion input into the microprocessor
which also is typically combined into the reference accuracy. Generally, there is only one
module associated with this conversion, thus combining uncertainties from multiple modules is
not applicable. The NTSP is determined from the AL as described in section 4.2.3 of the
topical report. Once the appropriate channel uncertainty has been determined based on the
reference accuracy for the digital instrument channel, the AV, ALT, and AFT can be
determined for use during surveillance testing following the methods described in the topical
report.
Configuration control measures will be applied as part of the setpoint control program to
maintain instrument setpoint databases for digital systems ensuring installed trip setpoints are
installed and programmed as required. The online diagnostics of most digital platforms
continually perform system checks and self-report errors or faults associated with digital
channels.
During periodic surveillance testing, the test is a simple verification that the digital channel
processes channel trips as determined by the digital signal processing within the AFT band.
The results are evaluated and the operability determination steps are identical. However,
typically, if the channel trip setpoint is found to be outside of the AFT band, this would indicate
a failure with the digital channel and the faulty components will require replacement. There is
typically no ability to re-calibrate the setpoint.
Page 16 of 20
R0003-08-002089-A.
Page 47 of 113 Januar 2013, Revision 3
" Is margin correctly shown as 5.5 psig?
" Using example problem and Notes 1& 2 from Figure 5.1, what would AV, Margin 2
and AFTTOT be if Margin I is 5.5 psig (allowed by note 1) versus 55 psig?
B&W NE Response
Appendix A Figure A.2 contains a typographical error where the margin was incorrectly shown
as 5.5 psig. The proper value for the margin as determined in this example is 5.0% of the span
which is 55.0 psig.
Based on the revision to Figure 5.1 and section 4.2.4 discussed in response to Question
07.01-C Appendix-9, the relationship between the allowable value, as-found and as-left
tolerances is more clearly understood. Figure A.2 has been revised to more clearly illustrate
the relationships in the example between the AFT and ALT as shown below:
CU = 314 psig
Margin 5z0 pssg
AV-075 7 psq
At TF*) =66 I psag
AF,.= M tC"w
NUL = 892.0 psig
N4omrl Opera"ig Range
Figure X.2: Relationship, between analytical limit and calculated oetpoints
Page 17 of 20
R0003-08-002089-A
* Using AFTTOT +/- 15.1 psig (-15.1 psig), what would be the operating margin (OM) as
described in Section 4.2.6 in order to avoid potential spurious channel trips?
* Is the methodology described in 4.2.6 sufficient for all cases?
B&W NE Response
Additional information was included in the example presented in Appendix A to specify the
normal upper limit (NUL) is 892 psig. Therefore, when applying equation 4.2.6'for an
increasing process the operating margin (OM) is calculated as follows:
OM = NTSP - NUL (increasing setpoint).
While this particular case is a simple example to demonstrate the application of the setpoint
methodology, the methodology to determine the operating margin described in section 4.2.6 is
sufficient and conforms with RG 1.105, revision 3 (Figure 1) that shows the operating margin is
simply the difference betweenthe normal operating range of the process variable and the
NTSP. If, during worse cases-the setpoint were to drift to the lower range of operability, the
operating margin would be sufficient to minimize spurious channel trips.
This additional calculation will be added to the example in Appendix A, page A-4, with changes
UM' - NOWL ------- n sei t)-= 9"60.6 psg - 892.0 pP _f.6 ofpsig0
Page 18 of 20
R0003-08-002089-A
environment does not specify seismic effects as described in section 4.3.1.1 paragraph 2 and
equation 4.2.1. Is seismic considered in figure 4.1 and if so how would this be applied to the
setpoint calculation for normal, seismic, and other postulated accident conditions, as.
applicable?
B&W NE Response,
The flow path presented in Figure 4.1 (page 9) was provided for illustrative purposes to
demonstrate how, for instrument channels in harsh environments, the additional evaluation of
uncertainties is required. It was not intended to list all uncertainty contributions for instrument
channels subject to harsh conditions during normal or postulated design basis accident
conditions in this figure..
The method for treating channel uncertainties for portions of the instrument channel that are
subject to harsh environments during normal, seismic and other postulated design basis
accidents is included in the current text in section 4.1.3.1 (pages 13-14) in the topical report.
The existing applicable portions of this section that explicitly include the uncertainties due to
seismic effects are shown in the boxed sections below.
There are no changes to the topical report in response to this question.
4.1.3.1 Contributing Uncertainties
The environment is analyzed and classified as mild or harsh. The environment in any plant area
is considered harsh if, because of postulated accidents, the temperature, pressure, relativity
humidity, vibration (seismic displacement), or radiation significantly increases above the normal
conditions. A mild environment is an environment that at no time is more severe than the
expected environment during normal plant operation, including anticipated operational,
occurrences.
For portions of the instrument channel that are located in a harsh environment, the accident
process measurement effects are determined (e.g., reference leg heat-up, density changes,
radiation exposure, seismic experience, etc.)and the uncertainties are determined. For portions
of the instrument channel that are located in a mild environment, the normal process
measurement effects are identified and uncertainties are determined. All uncertainties are
,-included as applicable.
After the environmental conditions are determined, the potential uncertainties affecting each
portion of the channel are identified.
Uncertainties are classified as random or non-random (Section 3.2). This determination is an
interactive process requiring the development of assumptions and, where possible, verification
of assumptions based on actual data. The determination of type of uncertainty establishes
whether the SRSS method can be used or if the uncertainty is to be added algebraically, or a
combination of both.
Elements of uncertainty for any module that are considered are listed below (not all of~the
uncertainties listed apply to every measurement channel). Definitions, as appropriate, are'
provided in Appendix B.
Page 19 of 20
R0003-08-002089-A
'RAI No. 6236 Ltr. No. 4'
process measurements effect
primary element accuracy
drift
temperature effects
radiation effects
static and ambient pressure effects
overpressure effect
measuring and test equipment uncertainty
power supply effects
indicator reading uncertainty
conversion accuracy
I a seismic effects I -
environmental effects - accident
as-left tolerance
as-found tolerance
propagation of uncertainty through modules
Page 20 of 20
Section F
R0003-08-002089-A Page 52 of 113
B:W
babcock & wilcox
6 109 ramsey place & lynchburg va 24501 # phone 434.316 7592
fax 434 316 7534 P www babcock corn
May 21, 2012 MPWR-LTR-12-00051
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
Babcock & Wilcox Nuclear Energy, Inc. (B&W NE)
Project Number-776
Subject: Babcock & Wilcox Nuclear Energy (B&W NE) Revised Response to Request for
Additional Information No.6236, RAI Letter No.4 for Appendices 5, 6, 9, 11 and 13.
References: 1. B&W NE Instrument Setpoint Methodology Topical Report 08-00289-001
2. Request for Additional Information Letter No.4 for the Review of Babcock &
Wilcox (B&W) mPower Reactor Project Instrument Setpoint Methodology
Topical Report 08-002-2089 [sic] Revision 1
3. B&W NE Response to NRC Request for Additional Information dated
February 2, 2012 (BW-JAH-2012-277)
By letter dated June 30, 2011, B&W NE submitted, for U.S. Nuclear Regulatory Commission
(NRC) staff review, Topical Report (TR) 08-0022089, Revision 1, (Reference 1 above).
Subsequently, NRC issued a Request for Additional Information (RAI) on December 22, 2011
(Reference 2 above). On February 2, 2012, B&W NE submitted a response to the RAI,
(Reference 3 above). Recently, in a conference call on March 3, 2012, the NRC staff requested
that B&W NE provide additional clarification regarding our RAI response related to Appendices
5, 6, 9, 11 and 13. The requested clarification is provided in the enclosures as discussed below.
Enclosure I is the revised response to the referenced RAI that includes the proposed
clarification and appropriate revision of TR information. Enclosure 2 is a markup of the original
RAI response (Reference 3) provided to facilitate the NRC's review. In addition Enclosure 3 is
the revised Instrument Setpoint Methodology Topical Report that incorporates changes
consistent with the revised RAI response.
Questions concerning this submittal may be directed to Jeff Halfinger at 434-316-7507 (email:
iahalfinaer(babcock.com) or Peter Hastings at 704-625-4978 (email:
pshastinas@_.enerationmpower.com).
P, echoloy Deloment
B&W NE
JAH/jlr
babcock & wilcox nuclear energy mc a Patoro, Vv'vico' (;m"(1fcnIr;
R0003-08-002089-A Page 53 of 113
B:W
babcock & wilcox :
0 109 ramsey place # lynchburg, va 24501 * phone 434 316.7592
6 fax 434 318 7534 D www.babcock.com
U.S. Nuclear Regulatory Commission
May 21, 2012
Page 2
Enclosures:
1. B&W NE's revised response to RAI No. 6236 Appendices 5, 6, 9, 11 and 13
2. B&W NE's revised response to RAI No. 6236 Appendices 5, 6, 9, 11 and 13 (Markup)
3. Instrument Setpoint Methodology Topical Report, dated May 2012 (R0003-08-002089,
Revision 003)
cc:
Joelle L. Starefos, NRC, TWFN 9-F-27
Joseph F. Williams, NRC, TWFN 6-E-4
babcock & wilcox nuclear energy inc a Babcnoc;;< & Aii'cX c onp.any
R0003-08-002089-A
Enclosure 1
B&W NE's revised response to the RAI No. 6236.
Appendices 5, 6, 9, 11 and 13
R0003-08-002089-A Page 55 of 113
RAI. No. 6236 Ltr. No. 4
Enclosure I
Babcock & Wilcox Nuclear Energy, Inc. Revised Response to
RAI Letter No. 4 for Appendices 5, 6, 9,11, 13
B&W mPower Pre-Appli cation Activities
Docket-No. PROJ 0776
Figure 4.1 - The setpoint steps'at the bottom of the figure (below the step "Determine the
Setpoint, and Allowable Value'), deviate from ANSI/ISA 67.04.02 Figure 2. Explain how this
B&W NE Response
Figure 4.1 of theB&W Instrument Setpoint Methodology is similar to Figure 2 in ANSI/ISA
67.04.02-2000, slightly am plified to provide more prescriptive guidance for obtaining the trip
setpoint (NTSP) from the analytical limit (AL) based upon either an increasing or decreasing ,
direction of the process variable. Figure 4.1 contains additional information not contained in
Figure 2 of ANSI/ISA 67.04.02-2000, this additional information has been removed.
The equation in section 4.2.3 for calculating the trip setpoint (NTSP).and limiting trip setpoint
LTSP'= AL + CU
NTSP = AL (CU + Margin)
Therefore, When following the guidance illustrated in Figure'4.1, and applying the mathematical
For cases where the process signal decreases towards the'analytical limit, NTSP and LTSP
calculated as follows:
subtracted from theAL to obtain the LTSP, and the.CU plus margin (if any) is subtracted from
the AL to obtain the NTSP.- For a'decreasing process,'the CU is added to ,the ALto obtain the
LTSP, and the CU plus margin (if any) is added to the AL to obtain the NTSPI. ,This, is
2000.
These methods are consistent with the guidance in RG 1.105 forestablishment of the LTSP as
the LSSS. The LTSP is-determined by subtracting the CU from the AL for-an increasing
Page 1 of 9
process, and adding the CU to the AL for a decreasing, process. To determine the NTSP, a
value for safety margin may be added to the CU to add conservatism when establishing the
Equation 4.2.3 (page 18) of the topical report has been slightly modified to more clearly show
the mathematical relationship for calculation of the LTSP and NTSP explicitly for increasing
and decreasing processes as shbwn below:
4.2.3 Trip Setpoint
LTSP = AL - CU (incr
LTSP = AL + CU. (dec
NTSP = AL - (CU + Margin)
*easing process)
reasing process)
(increasing pr6cess).
(decreasing process)
Figure 4.1 has been revised as shown on the following page.
Page 2 of 9
R0003-08-002089-A Page 57 of 113
a'
0I
U'
5)1
Note: Numbers in Brackets Refer to
the Paragraph of the Methodology
Described in this Report
Figure 4.1: Setpoint Calculation Flow
Page 3 of 9
R0003-08-002089-A
B&W NE Response
The list in section 4.1.3.1 lists the various elements of uncertainty for a module and is not
intended to be all inclusive, but typical for an instrument channel. The terms "as-left tolerance
specification" and ".as-found specification" should have matched the terms defined in Appendix
B. B&W recognizes that confusion was introduced since the names for the terms do not
exactly match those definitions provided in Appendix B. Therefore, the list in paragraph 5 of
section 4.1.3.1 (pages 13-14), as shown below, has been revised to exactly match the defined
terms provided in Appendix B as shown below and provide clarification that the list is not all
inclusive but is typical for an instrument channel.
uncertainties listed apply to every measurement channel). This list is not intended to be all
inclusive but is typical for the instrument channel. Definitions, as appropriate, are provided in
Appendix B.
* process measurements effect
* primary element accuracy
* drift
* radiation effects
* power supply effects
* seismic effects
* environmental effects - accident
* as-left tolerance
* as-found tolerance
* propagation of uncertainty through modules
Page 4 of 9
AFT and AV (see below).
sides of NTSP on Figure 5.1?
Section 4.2.5 - How is AFTn calculated as a +/- value?
" Section 4.2.4 Explain why the definition of Margin is different from Note 2
on Figure 5. 1.
" Is Margin (Note 2) correctly shown on Figure 5.1? see bullet 1 above.
B&W NE Response
To clarify the relationship between Margin and NTSP, AFT and AV a number of changes were
made to Figure 5.1 and the text contained in Sections 4.1.5, 4.2.4, 4.2.5, and 4.2.7 of the
topical report.
trip setpoint have occurred which could be signs of the channel malfunctioning. Thus a concept
of a double-sided acceptance criteria band for the measured trip s.etpoint during surveillance
Section 4.1.5 (page 15) has been revised, as shown below, to clarify that the margin must be
greater than or equal to the as-found tolerance to ensure the AV never exceeds the LSSS.
The NTSP is established for normal plant operation by adding margin to the total channel
uncertainty. The margin associated with the establishment of the NTSP is discretionary based
on engineering judgment to add a level of conservatism. Typically, margin would be applied to
account for such factors as conservatively rounding to the nearest engineering unit or
accounting for any assumptions used in determination of initial channel setpoints. The margin
applied also takes into consideration the operating range for the instrument channel to ensure
the trip setpoint is not established too close to the operating range limits that may cause
spurious channel trips. The margin applied adds conservatism to move the NTSP farther from
the AL and must always be greater than or equal to the as-found tolerance to guarantee the
allowable value will never exceed the LSSS. By definition, -the NTSP is equal to or more
conservative than the LTSP.
margin term in the determination of the AV, and includes the proper mathematical operator (+)
to ensure the double-sided band is correctly applied as shown below:
Page 5 of 9
R0003-08-002089-A,
Page 60 of 113
AV = NTSP t AFTTOT
Where:
AFTTOT - Total as-found tolerance for the entire instrument channel.
To protect against potential masking of equipment degradation during periodic surveillance
testing, no margin is included as part of the AV determination and the AFTTOT is applied as a
double-sided band around the NTSP.
calibration being performed. Therefore, when considering AV, AFTTOT is based on;
AFTTOT =+(AFT
1
2
+ AFT
2
2
+ .... +....+...+AFTn
2
)
1
/2
Where:
AFTn = as-found tolerance for module "n" (see 4.2.5).
Section 4.2.7 (page 22) has been revised to clarify that the margin.must be greater than or
equal to the as-found tolerance to ensure the AV never exceeds the LSSS as shown below:
Safety margin is a discretionary value determined by engineering judgment. Margin is applied
to accommodate normal expected conditions between surveillance intervals (e.g., drift). The
applied margin must ensure that NTSP + AFTTOT does not exceed the allowable value. The
minimum margin prevents expected channel drift from exceeding the AV.
Figure 5.1 has been updated to properly illustrate the application of a double-sided band for
the AFTTOT as applied to the NTSP to ensure consistency with revisions to equation 4.2.4
following bulleted items. The revised figure is shown on the following page.
* Illustration of regions of different conditions that may exist during periodic surveill ance
" Removal of the margin applied to the AFTTOT and its associated note (Note 2). (To
Identification that the margin must be greater than or equal to AFTTOT to ensure the AV
remains less than or equal to the LSSS (Note 1).
Page 6 of 9
R0003-08-002089-A
,lnu l ast- V AfalVSlS arlo UesI1 n 1 asis
SAFETY LIMIT (SL)
ANALYTIC LIMIT - - _-_-_-__-_-_-_
(AL) 1
CHANNEL
UNCERTAINTY (CU)
[Equation 4.2.21
LIMITING TRIP
SETPOINT (LTSP)
[Equation 4.2.3]
[Equation 4.2.3]
AS-LEFT
TOLERANCE
(ALT)
B
[Equation 4.2.4]
TOTAL AS-FOUND
TOLERANCE BAND (AFT.oT)
[Equation 4.2.5]
NORMAL
[Equation 4.2.6]
NORMAL OPERATING
UPPER LIMIT (NUL)
OPERATING RANGE
Recalibration is required and must be evaluated
SYSTEM SHUTDOWN
PROCESS PARAMETER
NOTES:
Page 7 of 9
, Is margin correctly shown as 5.5 psig?
* Using example problem and Notes I& 2 from Figure 5.1, what'wouldAV, Margin 2
and AETTOT be if Margin 1 is 5.5psig (allowed by note 1) versus 55 psig?
B&W NE Response
which is 55.0 psig.
the relationshipsin the example between the AFT and ALT as shown below. Additionally,
clarification has been added to indicate that the applied margin must be greater than or equal
to the as-found tolerance to ensure than the AV never exceeds the LSSS.
The text on page A-3 has been revised as shown below:
LTSP and NTSP are determined as follows for an increasing process using equation 4.2.3. A
margin of 5.0% of span (55 psig) is applied in accordance with Section 4.2.3 to the NTSP, which
is based on engineering judgment to include room for initial assumptions used in the calculation
uncertainties and to account for rounding errors. The LTSP is the LSSS used in the plant
technical specifications that protects the AL to satisfy 10 CFR 50.36. The applied margin must
ensure that NTSP + AFTTOT does not exceed the allowable value. The minimum margin
prevents expected channel drift from exceeding the AV.
CU = 31.4 psig
LSSS-*
MarginAF-rToT-
= 55.0 psig
AL = 1047.0 psig
LTSP =1015.6 psig
AV=975.7 psig
.ALTH )=g66.1 psg
ITALT 5.5opsig I AFTro=t 15.1 psig
NTSP = 960.6 psig
A.,TJ-)= 955.1 psig
AW945.5 psig
Operating Margin = 68.6 psig
Normal Operating Range
NUL = 892.0 psig
Figure A.2: Relationships between analytical limit and calculated setpoints
Page 8 of 9
R0003-08-002089-A
setpoint calculation for normal, seismic, and other postulated accident conditions, as
applicable?
B&W NE Response
The flow path presented in Figure 4.1(page 9) is provided for illustrative purposes to
uncertainties is required. It was not intended to list all uncertainty contributions for instrument
conditions in this figure.
Section 4.1.3.1 has been revised, as shown below, to add clarification and indicate the most
limiting uncertainty will be applied for portions of an instrument channel subject to a harsh
environment during postulated DBAs.
expected environment during normal plant operation; including anticipated operational',
occurrences.
For portions of theinstrument channel that are located in a harsh environment, the accident
radiation exposure, seismic experience, etc.) and the uncertainties are determined. The most
limiting uncertainities (temprature, radition, etc.) wil be applied. For portions of the instrument
channel that are located in a mild environment, the normal process measurement effects are
identified and uncertainties are determined. All uncertainties are included as applicable.
Page 9 of 9
R0003-08-002089-A
Page 64 of 113
January 2013, Revision 3 ,
Enclosure 2
B&W NE's revised response to the RAI No. 6236
Appendices 5, 6, 9, 11 and 13
(Markup)
babcock & wilcox nuclear energy, inc., a Babcock & Wilcox conmpaily
Enclosure 2
Babcock & Wilcox Nuclear Energy, Inc. Revised Response to
RAI Letter No. 4 for Appendices 5, 6, 9, 11, 13
B&W mPower Pre-Application Activities
Figure 4.1 - The setpoint steps at the bottom of the figure (below the step "Determine the
Setpoint and Allowable Value'), deviate from ANSI/ISA 67.04.02 Figure 2. Explain how this
B&W NE Response
Figure 4.1 of the B&W Instrument Setpoint Methodology is similar to Figure 2 in ANSI/ISA
67.04.02-2000, slightly amplified to provide more prescriptive guidance for obtaining the trip
setpoint (NTSP) from the analytical limit (AL) based upon either an increasing or decreasing
direction of the process variable. The amplified portion of Figure 4.1 ref9eS to 6ection 4.2.3 for
the m1thi4etm;Flatical equation to use for ca-lrulating of the tFrip etpeiRt and provides guidance on
the use of the equation. based upon the dircctiO of the proceSS va..iabl. 6, Figure 4. 1 contains
additional information not contained in Figure 2 of ANSI/ISA 67.04.02-2000, this additional
information has been removed.
The equation in section 4.2.3 for calculating the trip setpoint (NTSP) and limiting trip setpoint
LTSP = AL CU
NTSP = AL (CU + Margin)
Therefore, when following the guidance illustrated in Figure 4.1, and applying the mathematical
For cases where the process signal *iReeases-decreases towards the analytical limit, NTSP
and LTSP calculated as follows:
subtracted from the AL to obtain the LTSP, and the CU plus margin (if any) is subtracted from
the AL to obtain the NTSP. For a decreasing process, the CU is added to the AL to obtain the
LTSP, and the CU plus margin (if any) is added to the AL to obtain the NTSP. This is
2000.
Page 1 of 9
R0003-08-002089-A
These methods are consistent with the guidance in RG 1.105 for establishment of the LTSP as
the LSSS. The LTSP is determined by subtracting the CU from the AL for an increasing
process, and adding the CU to the AL for a decreasing process. To determine the NTSP, a
value for safety margin may be added to the CU to add conservatism when establishing the
No hange. to Figuro 4.1 will bo mado; however ,equation 4.2.3 (page 18) of the topical
report will-behas been slightly modified to more clearly show this-the mathematical relationship
for calculation of the LTSP and NTSP expicitly for increasing and decreasing processes wth
changes highlighted in shadcd tcxt as shown below:
4.2.3 Trip Setpoint
LTSP = AL - CU (inc
LTSP = AL + CU (dec
NTSP = AL - (CU + Margin)
reasing process)
reasing process)
(increasing process)
I Figure 4.1 has been revised as shown on the following page.
Page 2 of 9
R0003-08-002089-A Page 67 of 113
Block Diagram Instrument Channel
(4.1.1)
Determine the Required Actuation Functions and Process/
Environmental Conditions Assumed for Each Function
(4.1.2)
Determine the Uncertainty Allowance for the Channel
(4.1.3)
I -
*1
a
31
0I
Oi
a
1
w
SI
~I.
I.
lassify Each Module Harsh
Envi nment
(413.1)
Milda
Identify Accident Process Measurement
Effects (Ref. Leg Heatup, etc.)
(4.1.3.1)
Identify Normal Process Measurement
Effects (Head Effects, etc.)
(4.1.3.1)
Identity Accident Equipment Uncertainty
(Accident Temperature Effects, etc.) Apply
the most limiting value
1(4.1.3.1)
Identify Normal Instrument Uncertainties
(Drift, Normal Temperature Effects, etc.)
(4.1.3.1)
Identify Other Normal Effects
(4.1.3.1)
I~dentity
Uncertainty
Contributions
(4.1.3. 1)
Identify Other Accident Effects (IR, etc.)
Classify Each Uncertainty (Random, Bias, etc.)
1 1 (4.1.3.1)
Determine Module Uncertainties and
Combine for Channel Uncertainty
(4.1.4)
Determine the Setpoint and Allowable Value
(4.1.5 &.4.1.6)
Described in this Report
Page 3 of 9
B&W NE Response
The list in section 4.1.3.1 lists the various elements of uncertainty for a module and is not
intended to be all inclusive, but typical for an instrument channel. The terms "as-left tolerance
specification" and "as-found specification" should have matched the terms defined in Appendix
B. B&W recognizes that confusion was introduced since the names for the terms do not
exactly match those definitions provided in Appendix B. Therefore, the list in paragraph 5 of
section 4.1.3.1 (pages 13-14), as shown below, will behas been revised to exactly match the
defined terms provided in Appendix B as shown with chaRngo highlighted in shadcd text below
and provide clarification that the list is not all inclusive but is typical for an instrument channel.
uncertainties listed apply to every measurement channel). This list is not intended to be all
inclusive but is typical for the instrument channel Definitions, as appropriate, are provided in
Appendix B.
* process measurements effect
* primary element accuracy
" drift
temperature effects
* radiation effects
" overpressure effect
" power supply effects
" indicator reading uncertainty
* seismic effects
" as-left tolerance
" propagation of uncertainty through modules
Page 4 of 9
R0003-08-002089-A Page 69 of 113
AFT and AV (see below).
sides of N TSP on Figure 5.1?
" Section 4.2.5 - How is AFTn calculated as a +/- value?
* Section 4.2.4 - Explain why the definition of Margin is different from Note 2
on Figure 5.1.
/ Is Margin (Note 2) correctly shown on Figure 5.1 ? see bullet I above.
B&W NE Response
To clarify the relationship between Margin and NTSP, AFT and AV a number of changes were
made to Figure 5.1 and the text contained in Sections 4.1.5, 4.2.4, and-4.2.5, and 4.2. 7of the
topical report.
trip setpoint have occurred which could be si gns of the channel malfunctioning. Thus a concept
of a double-sided acceptance criteria band for the measured trip setpoint during surveillance
Section 4.1.5 (page 15) has been revised, as shown below, to clarify that the margin must be
greater than or equal to the as-found tolerance to ensure the A V never exceeds the LSSS.
The NTSP is established for normal plant operation by adding margin to the total channel
uncertainty. The margin associated with the establishment of the NTSP is discretionary based
on engineering judgment to add a level of conservatism. Typically, margin would be applied to
account for such factors as conservatively rounding to the nearest engineering unit or
accounting for any assumptions used in determination of initial channel setpoints. The margin
applied also takes into consideration the operating range for the instrument channel to ensure
the trip setpoint is not established too close to the operating range limits that may cause
spurious channel trips. The margin applied adds conservatism to move the NTSP farther from
the AL and must always be greater than or equal to the as-found tolerance to guarantee the
allowable value will never exceed the LSSS. By definition, the NTSP is equal to or more
conservative than the L TSP.
margin term in the determination of the AV, and includes the proper mathematical operator (+)
to ensure the double-sided band is correctly applied as shown below with the changos
highlighted in the shaded t5xt
Page 5 of 9
AV = NTSP AFTTOT
Where:
NTSP Trip setpoint.
AFTTOT = Total as-found tolerance for the entire instrument channel.
To protect against idnatonof-potential masking of equipment degradation during periodic
surveillance testing, no margin is included as part of the AV determination and the AFTTOT is
applied as a double-sided band around the NTSP.
calibration being performed. Therefore, when considering AV, AFTTOT is based on;
AFTTOT =+(AFT
1
2
+ AFT
2
2
+....+....+...+AFTn
2
)
1
/2
Where:
AFTn = as-found tolerance for module "n" (see 4.2.5).
Section 4.2.7 (page 22) has been revised to clarify that the margin must be greater than or
equal to the as-found tolerance to ensure the AV never exceeds the LSSS as shown below:
Safety margin is a discretionary value determined by engineering judgment. Margin is applied
to accommodate normal expected conditions between surveillance intervals (e.g., drift). The
applied margin must ensure that NTSP + AFTTOT does not exceed the allowable value. The
minimum margin prevents expected channel drift from exceeding the AV.
Figure 5.1 has been updated to properly illustrate the application of a double-sided band for
the AFTTOT as applied to the NTSP to ensure consistency with revisions to equation 4.2.4
following bulleted items. The revised figure is shown on the following page.
* Illustration of regions of different conditions that may exist during periodic surveillance
* Removal of the margin applied to the AFTTOT and its associated note (Note 2). (To
* Identification that the margin must be greater than or equal to AFTTOT to ensure the A V
remains less than or equal to the LSSS (Note 1).
Page 6 of 9
R0003-08-002089-A
Plant Safety Analysis and Design Basis
SAFETY LIMIT (SL)
ANALYTIC LIMIT ------
------
(AL)
CHANNEL
UNCERTAINTY (CU)
[Equation 4.2.2]
LIMITING TRIP
SETPOINT (LTSP)
[Equation 4.2.3]
(I
[Equation 4.2.3]
B
AS-LEFT
TOLERANCE
(ALT)
B
[Equation 4.2.4]
TOTAL AS-FOUND
TOLERANCE BAND (AFTTOT)
(Equation 4.2.5]
NORMAL
[Equation 4.2.6]
NORMAL OPERATING
UPPER LIMIT (NUL)
OPERATING RANGE
SYSTEM SHUTDOWN
PROCESS PARAMETER
NOTES:
Page 7 of 9
R0003-08-002089-A
Question 07.01-C Appendix-11I
" Is margin correctly shown as 5.5 psig?
* Using example problem and Notes 1& 2 from Figure 5.1, what would AV, Margin 2
and AFTTOT be if Margin I is 5.5 psig (allowed by note 1) versus 55 psig?
B&W NE Response
which is 55.0 psig.
the relationships in the example between the AFT and ALT as shown below. Additionally,
clarification has been added to indicate that the applied margin must be greater than or equal
to the as-found tolerance to ensure than the AV never exceeds the LSSS.
The text on page A-3 has been revised as shown below:
L TSP and NTSP are determined as follows for an increasing process using equation 4.2.3. A
margin of 5.0% of span (55 psig) is applied in accordance with Section 4.2.3 to the NTSP, which
is based on engineering judgment to include room for initial assumptions used in the calculation
uncertainties and to account for rounding errors. The LTSP is the LSSS used in the plant
technical specifications that protects the AL to satisfy 10 CFR 50.36. The applied margin must
ensure that NTSP + AFTTOT does not exceed the allowable value. The minimum margin
prevents expected channel drift from exceeding the A V.
CU = 31.4 psig
LSSS -
MargninAFTToT
= 55.0 psig
AV=-9757 psig
A.LT(J+) = 9661 psig
AFTF =151 psig
NUL = 892.0 psig
-Normal Operating Range
Figure A.2: Relationships between analytical limit and calculated eetpoints
Page 8 of 9
R0003-08-002089-A
Page 73 of 113 January2013, Revision 3
setpoint calculation for normal, seismic, and other postulated accident conditions, as
applicable ?
B&W NE Response
The flow path presented in Figure 4.1(page 9) is provided for illustrative purposes to
uncertainties is required. It was not intended to list all uncertainty contributions for instru ment
conditions in this figure.
The applicabic pertions of this section that eXPlicGitly incl'ude the unGcertaintieG due to imc
effec-ts arc highlighted below.
Section 4.1.3.1 has been revised, as shown below, to add clarification and indicate the most
limiting uncertainty will be applied for portions of an instrument channel subject to a harsh
environment during postulated DBAs.
expected environment during normal plant operation, including anticipated operational
occurrences.
For portions of the instrument channel that are located in a harsh environment, the accident
radiation exposure, seismic experience, etc.) and the uncertainties are determined. The most
limiting uncertainities (temprature, radition, etc.) wil be applied. For portions of the instrument
channel that are located in a mild environment, the normal process measurement effects are
identified and uncertainties are determined. All uncertainties are included as applicable.
Page 9 of 9
R0003-08-002089-A
Section G
R0003-08-002089-A
Page 75 of 1.13 January 2013, Revision 3
Document No: Title: Rev:
SIGNATURES
POs B. fihr Rama
96
_ _ _ _ _ _ _ _
' ' Rocdger Magness _____ ____ ____
Signature
: , , IDale
Approved By.
Sodger MaguneD
i Signature
I
@2012 Babcock & Wilcox Nuclear Energy, Inc. All rights reserved.
Page l of v
Document No: Title: Rev:.
RECORD OF REVISION
Revisio0 n No. Dat Prepnr l OD6scriptina of ChangesI
0 10/18/20 10 B. K. Arnholt Original Issue
6/6/2011 B. K. Arnholt
1. Clarify Section 4.2.1 of the report to
describe the mathematical relationship
between the nominal trip set point
(NTSP) and the limiting trip set point
(LTSP).
2. Clarify the definition of margin.
3.Add to the report a typical calculation
(not design-specific)
showing the
determination of uncertainties, and
application of the setpoint methodology
for a typical instrument channel with
resulting sample results for the
analytical limit (AL), the channel
uncertainty (CU), LTSP, NTSP, and the
allowable value (AV).
4. Remove references to the use of a
"graded approach."
5.Revise Figure 5.1 to:
a. Clarify the relationships between
design and safety analysis methods
*and methods applied during
surveillance and calibration.
b. Clarify that as-found tolerance is
derived from the NTSP to establish
the allowable value.
c. Clarify that the allowable value is the
limiting safety system setting (LSSS).
d.Clarify the relationship between the
LTSP, the NTSP, and the AV in the
main body.
2012 Babcock & Wilcox Nuclear Energy, Inc. All rights reserved.
.Page iii of v
R0003-08-002089-A Page 77 of 113
Document No: Title:
Rev:
Incorporate revisions to address requests
for additional information (RAls) received
from the NRC (Ref. RAI No. 6236 Ltr. No.
4).
1. Several editorial changes to add
clarity.
2. Clarify regulatory and standards
compliance.
3. Explicitly demonstrate the
2 1/12/2012 B.K. Arnholt relationships between as-found,
as-left tolerances including the
application of a double-sided
acceptance band.
4. Add specific criteria for evaluation
of channel operability during
periodic surveillance testing.
5. Update Appendix A to include
determination of the as-left band
and operating margin.
Incorporate revisions to address requests
for additional information (RAls) received
from the NRC (Ref. RAI No. 6236 Ltr. No.
4).
1. Revise Figure 4.1 to delete the
branch flow paths for
increase/decrease
processes.
2. Revise section 4.1.3.1 list of
example uncertainties to clarify
that the list is not intended to be
all-inclusive, but is typical for
5/01/2012 I.A.Rana instrument channels.
3. Clarify. application of margin in
calculating the allowable value.
The margin must always be
greater than or equal to the as-
found tolerance to guarantee the
AV will never exceed the LSSS.
4. Clarify the treatment of accident
environment effects and seismic
uncertainties. The most-limiting
uncertainties will apply
Page iv of v
R0003-08-002089-A
F
Document No:
R0003-08-002089-A
Title:
Title:
Instrument Setpoint Methodology Topical Report
Rev:
003
I
TABLE OF CONTENTS
1. ABSTRACT ........................................................ 1
2. 'INTRODUCTION ..................................................... 2
3. BA C KG R O U N D .................................................................................................................... 3
3.1 R egulatory Basis .................................................................................................. 3
3.2 Uncertainties .................. ................................... 4
3.3 Random Uncertainties ............... ......... ....................... 4
3.4 Non-Random Uncertainties ............................................ 5
3 .5 A ssu m ptio ns ................................................................................................................ 5
4. METHODOLOGY ................................................................................................. 7
4 .1 A p p ro a c h ..................................................................................................................... 7
4 .2 E q u a tio n s .................................................................................................................... 17
5. SUMMARY/CONCLUSIONS ........................................................................................ 23
6. R EFER ENC ES ................................................................................................................. 25
6.1 Code of Federal Regulations ................... w ............................................................. 25
6.2 U.S. Nuclear Regulatory Guidance .............................................................. .... 25,
6.3 U .S . Industry G uidance ........................................................................................... 25
LIST OF APPENDICES
Appendix A - Example Setpoint Calculation for a Safety-Related Pressure Channel
Appendix B - Definitions
Page v of v
R0003-08-002089-A Page 79 of 113 January2013, Revision 3
1. ABSTRACT
This report describes the instrument setpoint methodology applied to the B&W mPower
TM
reactor
protection system and other important instrument setpoints associated with the B&W mPower reactor.
The protection system is a digital, integrated reactor protection and engineered safety features actuation
system implemented for the B&W'mPower reactor.
The primary purpose ,of the protection system is to detect plant conditions that indicate the occurrence of
a design basis event as defined by theplant safety analysis and initiate the plant safety features required
to mitigate the event. Thesesafety features consist of the automatic actuation of reactor trips and
engineered safety features actuation systems.
The methodology described in this topical report is used to establish technical specification setpoints for
the B&W mPower reactor protection system in accordance with 10 CFR 50.36. The scope of this report
documents the methodology for establishing safety-related trip setpoints and their associated
uncertainties to ensure the analytical limit applied to instrument trip setpoints is satisfied. An example
calculation for a typical instrument loop is included in this report to demonstrate the application of the
methodology.
Page 1 of 25
2. INTRODUCTION
Instrumentation and control (I&C) safety systems monitor and control critical plant parameters to ensure
safety limits are not exceeded under the most severe design b6sis accident or transient. Instrument
setpoints and allowable values for these I&C safety system critical process parameter functions are
chosen so that potentially unsafe or damaging process excursions (transients) can be avoided and
terminated before plant conditions exceed safety limits. Accident analysis establishes the limits for critical
process parameters. These analytical limits established by the accident analysis do not normally include
considerations for the accuracy (uncertainty) of installed instrumentation. This report describes the
method used for the B&W mPower reactor of identifying and combining instrument uncertainties, and
applying these uncertainties to establish trip setpoints for critical process parameters to ensure vital plant
protective features actuate at the appropriatesetpoint during transient and accident conditions.
The methodology described in this report is applied to safety-related equipment that performs a specific
safety function for uncertainty analysis, setpoint determination, and determination of allowable values to
protect the analytical limit. Determination of instrument setpoints for non-safety related equipment that
does not perform a specific safety function is controlled administratively by plant procedures. Typical
instrument setpoints in this category are established for equipment that supports reliable power
generation or equipment protection.
The results of the uncertainty evaluations can be applied to the following types of calculations:
a
a
a
Determination of safety-related setpoints
Extension of surveillance intervals
Determination of instrument indication uncertainties
Evaluation or justification of previously established setpoints
Important definitions and terminology used throughout this report are contained in Appendix B for
reference.
Page 2 of 25
Document No: Title:
Rev:
3. BACKGROUND
3.1 Regulatory Basis
10 CFR Part 50, Appendix B, Criterion XI, "Test Control," and Criterion XII, "Control of Measuring and
Test Equipment," provide requirements for tests and test equipment used in maintaining instrument
setpoints.
10 CFR 50, Appendix A, GDC 13, "Instrumentation and Control," requires in part that instrumentation be
provided to monitor variables and systems, and that controls be provided to maintain these Yariables and
systems within prescribed operating ranges.
10 CFR 50, Appendix A, GDC 20, "Protection System Functions," requires in part that the protection
system be designed to initiate automatically the operation of appropriate systems, including the reactivity
control systems, to assure that specified acceptable fuel.design limits are not exceeded as a result of
anticipated operational occurrences.
10 CFR 50.36(c)(1)(ii)(A), "Technical Specifications," requires that, where a limiting safety system setting
(LSSS) is specified for a variable on which a safety limit (SL) has been placed;& the setting must be so
chosen that automatic protective action will correct the abnormal situation before a safety level is
exceeded. LSSSs are settings for automatic protective devices related to variables with significant safety.
functions. Setpoints found to exceed technical specification limits are considered as malfunctions of an
automatic safety system. Such an occurrence could challenge the integrity of the reactor core, reactor
coolant pressure boundary, containment, and associated systems.
SRP Appendix 7.1-A refers to BTP 7-12 and Regulatory Guide (RG) 1.105 for guidance on establishing
and maintaining instrument setpoints. This guidance is designed to meet 10 CFR 50.36(c)(1)(ii)(A), 10
CFR50, Appendix A, GDC 13, GDC 20 and 10 CFR 50 Appendix B requirements.
The calculation of safety-related instrument setpoints for the B&W mPower reactor is based on RG 1.105,
which describes a method acceptable to the NRC for complying with the applicable regulations: RG
1.105 endorses the use of ISA-67.04-1994, Part I. Recognizing that RG 1.105, Revision 3, was published.
in 1999,,and to ensure the issues identified in RIS 2006-17 (Ref. 6.2.4) are addressed, the. B&W mPower
instrument setpoint methodology follows the guidance provided by ANSI/ISA-S67.04.01-2000 (Ref. 6.3.1),
which is equivalent to ISA 67.04-1994, Part I and ANSI/ISA-RP67.04.02-2000 (Ref. 6.3.2).
BTP 7-12 (Ref. 6.2.2) provides guidelines for reviewing the process that an applicant or licensee follows
to establish and maintain instrument setpoints for the following objectives:
* To verify that setpoint calculation methods are adequate to ensure that protective actions are
initiated before the associated plant process parameters exceed their analytical limits. I
" To verify that setpoint calculation methods are adequate to ensure that control and monitoring
setpoints are consistent with their requirements.
* To confirm that calibration intervals and methods established are consistent with safety analysis
assumptions.
Page 3 of 25
R0003-08-002089-A P Page 82 of 113 January 2013, Revision 3
3.2 Uncertainties
The methodology described in this report relies on the determination of the types of uncertaintq'. It is not
the intent of the report to provide a tutorial in statistical analysis but to provide a brief discussion on the
types of uncertainty, their dependency, and their statistical combinations.
Instrument uncertainties are categorized as Random or Non-Random, and arediscussed in Sections 3.3
and 3.4, respectively.
3.3 Random Uncertainties
Random uncertainties are referred to as a quantitative statement of the reliability of a single measurement
or of a parameter, such as the arithmetic mean value, determined from a number of randomtrial
measurements,. This is often called the statistical uncertainty and is one of the precision indices. The
-most commonly used indices,' usually in reference to'the reliability of the mean, are the standard
deviation, the standard error (also called the standard deviation, of the mean), and the probable eriror.
Typically, uncertainties specified by a manufacturer as having a + magnitude, are random uncertainties.
For these types of uncertainties, B&W uses 95/95 tolerance limits as an acceptable criterion (i.e., a 95%
probability that the constructed limits contain 95% of the population of interest for the surveillance interval
selected). Typical- manufacturers' published accuracy figures are at "2o" level with a 95.6% probability on
a normal error (Gaussian) distribution curve. Therefore, it is acceptable to combine these errors at "2c"-
(2 times standard deviation) value by the Square Root of the Sum of the Squares (SRSS) method.
RG 1.105 states: "The 95/95 tolerance limit is an acceptable criterion for uncertainties.' (Although the
95/95tolerance, limit has an actual confidence level of 1.96o, the methodology described in this report
uses 2a to simplify calculations and adds an additional level of conservatism)..
This methodology uses a double-sided acceptance criteria band for random uncertainties to ensure that
the instrument setpoint is maintained within a prescribed range as defined in Sections 4.2.2 and 4.2.3 of
this report, and deviations of the.trip setpoint beyond the acceptable tolerance range are identified and
corrected.
3.3.1 Independent Uncertainties
Independent uncertainties are those uncertainties for which no'common rootcause exists (i.e.,
uncertainty errors whose value at a particular future instant cannot be predicted with priecision but can
onlyr 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 given median value.. Therefore, random,
independent uncertainties are eligible for the SRSS combination propagated from the process
measurement module through the signal conditioning module of the instrument channel to the device that
initiates the actuation. It is generally accepted that most instrument channel uncertainties are
independent of each other.'
3.3.2 Dependent Uncertainties
Complicated relationships may exist between instrument channels and various instrument uncertainties.
As such, a dependency might exist between some random uncertainty terms and parameters of an
2012 Babcock.& Wilcox Nuclear Energy, Inc. All rights reserved.
Page. 4 of 25
R0003-08-002089-A Page 83 of 113 January 2013, ReVision 3
overall uncertainty analysis. A common root cause may exist which influences other uncertainty terms in
the analysis with a known relationship. When these uncertainties are included, they are added
algebraically, which results in a statistically larger value for that parameter when evaluated in the overall
channel uncertainty. These combined dependent uncertainties are then treated as an additional
independent random uncertainty, which can then be combined with other independent terms using the
SRSS method in the overall uncertainty calculation.
3.4 Non-Random Uncertainties
3.4.1 Bias
Bias uncertainties are those that consistently have the same algebraic sign. Bias terms are the fixed or
systematic uncertainty components within a measurement and are not generally eligible for SRSS
combinations. In some cases, they can be explicitly accounted for in the instrument channel calibration
process (i.e., calibrated out), in which case they are not accounted for in the uncertainty calculation since
they can be compensated for in the scaling of the instrumentation. Any bias effects that cannot be
calibrated out are directly accounted for in the uncertainty calculation.
If they are predictable for a given set of conditions because of a known positive or negative direction, they
are classified as bias with a known sign. If they do not have a known sign, they are treated
conservatively by algebraically adding the bias in the worst direction based on the nature of the
instrument channel. These are classified as bias with an unknown sign.
3.4.2 Abnormally Distributed Uncertainties
Some uncertainties not normally distributed may not be eligible for the SRSS combination and are
categorized as abnormally distributed. This type of uncertainty is treated as a bias against both the
positive and-negative components-of module uncertainty. Their unpredictable sign is conservatively
treated by algebraically adding the bias in the worst direction based on the nature of the instrument
channel.
3.5 Assumptions
The methodology for the determination and calculation of uncertainty terms, and ultimately the process
described in this report for determining setpoints, is based on the assumptions listed below:
" If both magnitude and direction of a bias are known (e.g., transmitter static pressure span
effects), this effect can be accounted for in the instrument channel calibration procedure and
calibrated out of an instrument and thus eliminated from the uncertainty calculation.
* Any random independent term whose value is less than 1/10 of any of the other associated
device random uncertainties can be statistically neglected.
" Uncertainty terms of devices are calculated in terms of percent calibrated span.
@2012 Babcock & Wilcox Nuclear-Energy, Inc. All rights reserved.
Page 5 of 25
R0003-08-002089-A Instrument Setpoint Methodology TopicaiReport 003
For the purposes of the setpoint analyses, the instrumentation is assumed to be calibrated based
on the ambient conditions in which the instrumentation components are expected to operate and
specified in the plant calibration procedures. ,The temperature effect (TE) for the instrumentation
accounts for possible differences between the temperature associated with the instrument
calibration and the ambient conditions of the installed equipment and is based on the temperature
deviation between this assumed calibration temperature and the maximum and minimum ambient
temperature of the specific location of the actual instrumentation. The normal temperature effects,
are accounted for as shown in the equations in Section 4.2.1. By using the actual vendor data
(typically stated in terms of X % span per Y OF), actual calibration temperatures and' plant
operating temperatures, the overall temperature effect is determined and accounted for in the TE
term for the specific instrument channel of interest, consistent with the guidance contained in
ANSI/ISA-RP67.04.02-2000 (Ref. 6.3.2).
Page 6 of 25
Document No: Title:
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4. METHODOLOGY
The B&W mPower methodology for uncertainty analysis, setpoint determination, calibration interval and
determination of allowable values for safety-related instrumentation follows the standards and I
recommended practices of ANSI/ISA-S67.04.01-2000 (Ref. 6.3.1) and ANSI/ISA-RP67.04.02-2000 (Ref.
6.3.2) with guidance provided by Regulatory Guide 1.105 (Ref. 6.2.1). The term "uncertainty' is used to
reflect the distribution of errors consistent with References 6.3.1 and 6.3.2.
This section provides the methodology used to establish the uncertainty of the instrument measurement
channel that includes all of the elements of uncertainty described below and then describes how the
calculated uncertainties are applied to the trip setpoints and allowable values. Uncertainties for
calculated functions or composed points (points that are made up of multiple inputs or calculated inputs)
are also discussed.
The general methodology described in this report used to combine instrument loop uncertainties is an
appropriate combination of those groups that are statistically and functionally independent. Those
uncertainties that are not independent are conservatively treated by arithmetic summation and then
systematically combined with other independent terms. Random and independent instrument loop
uncertainties are combined using the statistical SRSS approach with abnormally distributed and non-
random or bias uncertainties combined algebraically in accordance with ANSI/ISA-RP67.04.02-2000 (Ref.
6.3.2). The calculation methodology for the B&W mPower reactor follows the intent of the procedure
established in the ISA standard ANSI/ISA-S67.04.01-2000 (Ref. 6.3.1) and additional guidance on
combining instrumentation uncertainties provided in ANSI/ISA-RP67.04.02-2000 (Ref. 6.3.2).
The methodology described in this report addresses only the highest grade discussed in the standard
applied to those safety-related setpoints with established LSSSs forwhich a safety limit has been
established as defined by the plant safety analysis. All elements of uncertainty, both normal and accident
or abnormal conditions, are evaluated and addressed in instrument loop accuracy and setpoint'
calculations such that the results have a 95% probability with a 95% confidence (i.e., 95%/95% rigor).
There are manysafety-related and non-safety related system instrument setpoints that are important to
safety or important for reliable power generation and equipment protection. Because these setpoints may
not have analytical limits established by the accident analysis for a safety limit, the basis for the setpoint
calculation becomes system or equipment protection and maintaining generation capacity. The normal
process limit (NPL) adjusted for the appropriate margin becomes the basis for establishing the setpoint
when no analytical limit is established by the accident analysis and is governed and controlled by.plant
procedures.
4.1 Approach
The methodology follows the setpoint calculation flow depicted in Figure 2 of ANSI/ISA-RP67.04.02-2000
(Ref. 6.3.2), which has been reproduced as Figure 4.1, with minor modifications to add guidance for
applying channel uncertainties and margin based on whether an instrument channel signal approach to a
trip setpoint is decreasing or increasing. The instrument loop is diagrammed and analyzed as described
in the following subsections. The general relationships between the various setpoints and limits are
shown in Section 5, Summary.
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R0003-08-002089-A Page 86 of 113 'January 2013, Revision 3
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A typical calculation data sheet/checklist shown as Table 4.1 is used as a guide and to provide
consistency in the development of thecalculation(s). This table also provides traceability and
documentation of the loop data and uncertainties used. The results of the calculationare documented in.
accordance with controlled plant procedures and programs (such as the Setpoint Control Program) with
adequate. detail so that all bases, equations, and conclusions are fully understood and documented.
Table 4.1 includes a comprehensive list of all uncertainties that must be considered for inclusion in the
total channel uncertainty (CU) calculation.
2012 Babcock,& Wilcox Nuclear Energy, Inc. All rights reserved.
Page 8 of 25
.Block Diagram Instrument Channel
(4.1.1)
I
Determine the Required Actuation Functions and Process/
Environmental Conditions Assumed for Each Function
(4.1.2)
Determine the Uncertainty Allowa nce for the Channel
(4.1.3)
lassify Each Modules- Harsh
< Environment
(4.1.3.11)
Mild
4
Y
I
Identify Accident Process Measurement
Effects (Ref. Leg Heatup, etc.).
(4.1.3.1)
Identity Normal Process Measurement
Effects (Head Effects, etc.)
(4.1.3.1)
a
ldentiffy9-AidifE ipment ncertainty
(Accident Temperature Effects, etc.) Apply
the most limiting value
(4.1.3.1)
Identify Normal Instrument Uncertainties
(Drift, Normal Temperature Effects, etc.)
(4.1.3.1)
Identify Other Normal Effects
(4.1.3.1)
Identify Uncertainty Contributions
(4.1.3.1)
Identify Other Accident Effects (IR, etc.)
(4.1.3.1)
Classify Each Uncertainty (Random, Bias, etc.)
S(4.1.3.1)
Determine Module Uncertainties and
Combine for Channel Uncertainty
(4.1.4)
I
Determine the Setpoint and Allowable Value
(4.1.5 & 4.1.6 )
Described in this Report '
Page 9 of 25
R0003-08-002089-A Page 88 of 113
Document No: Title:. Rev:
Table 4.1: Calculation Data Sheet
ITEM DESCRIPTION REFERENCE REMARKS
(PARAMETER)
Component ID
Service Description
Location
Manufacturer
Model Number
Quality Category
Adjustable Range
Process Calibrated Range
Input Signal Calibrated Range
Output Signal Calibrated Range
Reference Accuracy (RA)
Drift (OR)
Bias (B)
Static Pressure Effect (SP)
External Pressurization Effect (EP)
Overpressure Effect (OP)
Temperature Effect - Normal (TE); Accident (TEA)
Humidity Effect (HE)
Radiation Effect - Normal (RE); Accident (REA)
Seismic Effect (SE)
Insulation Resistance Effect (IRE)
Power Supply Effect (PS)
Indicator Reading Uncertainty (R)
Process Measurement Effect (PM)
Primary Element Effect (PE)
Measurement & Test Uncertainty (MTE)
Technical Specification (If Applicable)
Analytical Limit (AL)
Normal Process Limit (NPL)
Allowable Value (AV)
Trip Setpoint (NTSP)
Calibration Frequency
Calibration Procedure
As-Found Tolerance (AFT)
As-Left Tolerance (ALT)
Module Algorithm
EQ and Functional Operating Environment
Safety Function/Other Functional Requirements
Function Duration
Normal Operation Upper Limit (NUL)
Normal Operation Lower Limit (NLL)
Operating Margin (OM)
Module Uncertainty (e:6):
Channel Uncertainty (CU):
Trip Setpoint (NTSP):
Allowable Value (AV):
As-Found Tolerance (AFT):
Operating Margin (OM):
Equation 4.2.1
Equation 4.2.2
Equation 4.2.3 (for calculated functions: Equation 4.2.7)
Equation 4.2.4
Equation 4.2.5
Equation 4.2.6
Page 10 of 25
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R0003-08-002089-A Instrument Setpoint Methodology Topical Report* 003
4.1.1 Loop Diagram
The loop is diagranimed to identify the various modules and interconnection devices that m ake up the
instrument loop. If necessary, multiple channel diagrams are developed. A typical process measurement
channel diagram is shown in Figure 4.2. The diagram shown is used to include the interfaces, functions,
sources of uncertainty, and the instrument module environments. Although the figure shows a flow
measurement loop, the layout is generally applicable to temperature, level, pressure, and other parameter
measurements.
A specified number of transmitters or sensors may be used to satisfy the requirements for redundancy
and reliability. If each independent instrument loop is functionally equivalent in terms of the types of
modules and environment, only one instrument channel diagram is needed. Each loop is analyzed and
arrangements and characteristics are compared to verify that all loops are identical. In this case, a single
calculation is valid for all of the loops.
Environmental boundaries are drawn for the channel as shown in the loop diagram. For simplicity, two
sets of environmental conditions are shown. The process measurement elements are usually located in
plant areas where a harsh environment may exist during the time the instrument loop must function. For
most channels, signal conditioning and actuation are located in mild environments.
4.1.2 Loop Function
The loop function is analyzed for its role in the system operation considering the following:
functional requirements
actuation functions
display functions
operating times
postulated environments
Page 11 of 25
STNFa MUL GAE fAGH
eMOMW4T' X FUN . 1N4 BMOM 'Er4IRLo41- BAnJvJALYcD~mLBfi;
PFF
TMfi flSG
RV-S-M E1c
01 M]
8r.R
EMOCNVW'N
UN33UM4ffA1Q/JNM
MOMM Br
UNIEM AIGNMI
[] RGIMMa.WERM
[01 OWMU~arNMW U E
M025AUOWN
R1 9JitZEW
anmrw~wCffrEMUiK
[N' WOrLNIaMMRa't DWErc OURMMLN3tWAOM1
Figure 4.2: Typical Instrument Channel Layout
@2012 Babcock.& Wilcox Nuclear Energy, Inc. All rights reserved.
Page 12 of 25
4.1.3 Uncertainty Analysis
Once the loop is diagrammed as described in Section 4.1.1', and the actuation functions, process and
environmentalconditions are established for each function, then the loop is evaluated, uncertainties
calculated, limits are established, and the trip setpoint is determined.
This methodology includes a rigorous' review of the instrument loop layout and'design. Each element of
uncertainty, for each' module or device is evaluated in detailand the estimated loop uncertainty, is
justified. Additional uncertainties that ma" apply to a particular instrument channel are accountedfor in
determining the trip setpoint allowance. Not all of the uncertainties listed apply to every'measurement
channel. The setpoint is carefully established with respect to the process analytical limit and the channel
Uncertainty,
The environment is analyzed and classified as mild or harsh. The environment in any plant area is
.considered' harsh if, because of postulated accidents, the temperature, pressure, relativity humidity,
vibration (seismic displacement) or radiation significantly increases above the normal conditions. 'A mild
environment is an environment that at no time is more severe, than the expected environment during,
-normal plan~t operation, including anticipated operational occurrences.
For portions of the instrumeht channel that are located.in a harsh:environment, the accident process
measurement effects are determined(e.g., reference leg heat-up, density changes, radiation exposure,
seismicexperience, etc:) and the uncertainties are'determined. The most limiting uncertainties.
(temperature, radiation, etc.) wil be applied. For portions of the instrument channel that are Iocated in a-.
mild environment, the normal process measurement effects are identified and' uncertainties are
determined. All uncertainties are included as applicable.
After the environmental conditions aredetermined,' the potential uncertainties affecting each portion of the
channel are identified.'
Uncertainties are classified as random or non-random (Section 3.2). This determination is an interactive
process requiring the development.of assumptions and, where possible, verification of assumptions
based on actual data. The determination.of type of uncertainty establishes whether the SRSS method
can be used or if the uncertainty is to be, added algebraically, or a combination of both..
Elements of uncertainty for ahy module that are considered are listed below (not all of the uncertainties
listed apply to'every measurement channel). This list is not intended to be all inclusive but is typical for
the instrument channel. D~efinitions, as appropriate, are provided in Appendix B. '
" process -measurements effect
. primary element accuracy
* drift
* radiation effects
static and ambient pressure effects
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R0003-08-002089-A Instrument Setpoint Methodology'Topical Report 003
0 measuring and test equipment uncertainty
0 power supply effects
* seismic effects
* as-left tolerance
propagation of uncertainty through modules
Individual module uncertainties and other uncertainty terms ,are combined to determine the overall
channel uncertainty (CU) using the equations shown in Sections 4.2.1 and 4.2.2, respectively.
As described earlier, the methodology used in this report to combine instrument loop uncertainties is an
appropriate combination of those groups that are statistically and functionally independent. Those
uncertainties that are not independent are conservatively summed algebraically creating a new, larger
independent uncertainty that are eligible for combination with other independent terms using the SRSS
method described in this report.
As can be seen from the equations, process measurement effect (PM) and primary element accuracy
(PE) are now accounted for. These parameters are considered independent of sensor and digital
process equipment parameters. The PM term provides allowances for the non-instrument related effects
such as velocity effects, fluid density changes, and'temperature changes. If additional, independent and
random PM terms apply, they can be combined using the SRSS methodology. The PE term typically is a
calculated or measured accuracy for the device and accounts for the accuracy of the device being
installed in the process (e.g., nozzles, venturis, orifice plates, etc.). The primary element uncertainties are
typically considered to be random, unless explicitly stated by the manufacturer and are accounted for in
the equations shown in Section 4.2.2 using the SRSS method.
The process measurement uncertainty consists of both random'and bias uncertainties. Random PM
uncertainties are appropriately treated using the SRSS method. PM bias uncertainties than cannot be
accounted for in the channel calibration (such as with a flow or level instrument channel) and eliminated,
are included in the bias term of the equations shown in Section 4.2.2.
Note that the CU also includes the module uncertainty (e) for each module. A "module" is defined inthis
methodology as any assembly of interconnecting components that constitutes an identifiable device,
instrument or piece of equipment. This includes any elements in the channel attributed to the digital
system where there are random errors.
As stated earlier, error propagation for signal conditioning modules (when they are selected and defined)
is combined using the guidance in ANSI/ISA-RP67.04.02-2000, Annex K (Ref. 6.3.2).
4.1.5 Trip Setpoint
The nominal trip setpoint (NTSP) and limiting trip setpoint (LTSP) are calculated using equation 4.2.3.
2012 Babcock,& Wilcox Nuclear Energy, Inc. All rights reserved.
Page 14 of 25
Document No: Title:
Rev:
The trip setpoint (NTSP) cannot be established until the analytical limit (AL) is defined by the safety
analysis. Any inherent margins in the analytical limit are quantified in the determination of the trip
setpoint.
The analytical limit is the limit of a measured or calculated variable established by the safety analysis for
the actuation of protective functions. Actuating protective functions at or before the analytical limit
ensures that the safety limit (SL) is not exceeded and design conditions of equipment/systems assumed
in other analyses are not exceeded. Analytical limits are developed from event analysis models that
consider parameters such as process delays, control rod insertion times, reactivity changes, instrument
response times, etc.
The limiting trip setpoint (LTSP) is the limiting safety system setting that accounts for all known channel
uncertainties associated with the instrument channel. The LTSP is determined from the AL and provides
reasonable assurance that the trip or actuation will occur before the AL is reached regardless of the
process or environmental conditions effect on the instrumentation.
The NTSP is established for normal plant operation by adding margin to the total channel uncertainty.
The margin associated with the establishment of the NTSP is discretionary based on engineering
judgment to add a level of conservatism. Typically, margin would be applied to account for such factors.
as conservatively rounding to the nearest engineering unit or accounting for any assumptions used in
determination of initial channel setpoints. The margin applied also takes into consideration the operating
range for. the instrument channel to ensure the trip setpoint is not established too close to the operating
range limits that may cause spurious channel trips. The margin applied adds conservatism to move the
NTSP farther from the AL and mustalways be greater than or equal to the as-found tolerance to
guarantee the allowable value will never exceed the LSSS. By definition, the NTSP is equal to or more
conservative than the LTSP.
The allowable value (AV) is calculated using equation 4.2.4.
Periodic surveillance testing is required to verify the safety-related instrument channel performs as
required to protect the AL. The allowable value defines the maximum and/or minimum limits of
operability. It is the limiting value of the measured variable at which the trip setpoint or calibration setting
may be found during instrument surveillance to provide adequate assurance that the AL remains
protected. The allowable value is an LSSS specified in plant Technical Specifications. It is-used by the
plant to verify instrument channel operability at periodic surveillance intervals.
The AV is a value that the trip setpoint might have when tested periodically and accounts for instrument
drift and other uncertainties applicable to normal plant operation associated with the test during normal
plant operation including: instrument drift, reference accuracy, as-left tolerance from the previous
calibration and measurement and test equipment uncertainty. A setpoint found within the allowable value
region, but outside the as-found tolerance, is considered operable but degraded. It is acceptable with
respect to the analytical limit; however, the instrument must be reset to return it within the allowed as-left
tolerance region (see definitions). A channel setpoint found outside the allowable value region is
declared inoperable and an evaluation of acceptable channel functionality is performed. The channel is
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R0003-08-002089-Al Instrument Setpoint Methodology Topical Report 003
required to be calibrated to return the setpoint within the acceptable tolerance range. Plant-specific
procedures will maintain and track the results of the periodic surveillance test procedures and the
historical as-found and as-left data obtained during surveillance testing. These data will be evaluated to
confirm the assumptions for instrument channel drift and uncertainty data remain valid.
4.1.7 Calculated Functions (Composed Points)
Channel uncertainties for calculated functions or composed points (input points where two or more
signals are combined) are calculated using the methods described in ANSI/ISA-RP67.04.02-2000, Annex
K (Ref. 6.3.2). For these points, the most limiting safety margin assigned to each input parameter is
normalized (converted to the appropriate engineering units) and then summed together. The resulting
total safety margin (TSM)'is then used to determine NTSP.
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R0003-08-002089-A Instrument Setpoint' Methodology Topical Report 003
4.2 Equations
Equations that are used in preparation of calculations in this methodology are shown in the following
sections.
4.2.1 Module Uncertainty.
en+= +(RA
2
+DR
2
+TE
2
+HE
2
+RE
2
+ps
2
+sp
2
+op
2
+SE
2
+TEA
2
+REA
2
+EP
2
+ ALT
2
+MTE
2
+R
2
)1/
2
+ B+
e,= -(RA
2
+DR
2
+TE
2
+HE
2
+RE
2
+Ps
2
+sP
2
+op
2
+SE
2
+TEA
2
+REA
2
+Ep
2
+ ALT
2
+MTE 2+R)2 - B
Where:
en = Total module uncertainty. When all module uncertainties are combined to calculate'the
channel uncertainty, CU, the randomrportion of'the "ex" terms is placed under the square
root radical and the bias portions are combined algebraically.
RA = Sensor reference accuracy specified by the manufacturer.
DR = Drift of the sensor over a specific period. This has historically been the drift specified by
the. manufacturer.
TE = Temperature effect .for the sensor; the effect ofambient temperature variations on the
sensor. accuracy.
HE Humidity effect for the sensor;,the effect of changes in ambient humidity on sensor
accuracy, if any.
RE = Radiation effect for the sensor; the effect of radiation exposure~on sensor accuracy.
PS = Power supply variation effects; the uncertainty due to instrument power supply variations.
SP = Static pressure effects for the sensor; the effect of changes in process static pressure on
sensor accuracy.
OP = Overpressure effect; the effect of over ranging the pressure sensor of a transmitter.
SE = Seismic effect for the sensor; the effect of seismic oroperational vibration on the sensor
accuracy.
TEA Temperature effects during accidents; the uncertainty effects of adverse conditions due to
temperature on the instrument channel during a design basis accident.
REA Radiation effects during'accidents; the effect of adverse radiation environments on the
instrument channel during a design basis accident.
EP = The error of a specific instrument that is associated with ambient pressure variations.
ALT = Calibration setting tolerances for the sensor; the uncertainty associated with calibration
tolerances.
MTE Measurement and test equipment effect for the sensor; the uncertainties in the equipment
utilized for calibration 'of the sensor.
R = Readability error associated with display functions.
B = Bias associated with the sensor, if any.
2012 Babcock& Wilcox Nuclear Energy, Inc. All rights reserved.
Page 17 of 25
Document No: . Title: Rev:
Note that the possible sources of uncertainty above only include those associated with the sensor.
Similar terms for signal isolators, indicators, bistables or other signal conditioning instruments can be
combined in similar fashion to obtain an overall uncertainty expression for an entire instrument loop. The
random uncertainty terms would be included with the sensor random terms within the square root term.
The bias terms are combined according to their direction outside the square root radical.
Error propagation for signal conditioning modules (when they are selected and defined) is combined
using the guidance in ISA-RP67.04.02-2000, Annex K.
CU+ =+(PM2+ PE2 + e
1
2+ ..... +en2)1/2 + B+
CU- -(PM2 + PE2 + e12 ...... +en
2
)
1
/
2
- B-
Where:
CU = Total channel uncertainty (For the purpose of this methodology, the uncertainty is
calculated for a setpoint(s). It could also be the uncertainty for an indication function
or a control function. Because each function typically uses different end-use
devices, the channel uncertainty is calculated separately-for each function.)
PM = Random uncertainties that exist in the channel's basic process measurement.
PE = Random uncertainties that exist in a channel's primary element, if present, such as
the accuracy of a flow orifice plate.
el ... en = Total random uncertainty for each module in the loop from Module 1 through
Module n.
B+ is positive bias, and B- is negative bias.
4.2.3 Trip Setpoint
LTSP = AL - CU (incr
LTSP = AL + CU (dec
NTSP = AL - (CU +. Margin)
easing process)
reasing process)
(increasing process)
Where:
LTSP
NTSP
= Limiting trip setpoint.
= Nominal trip setpoint.
Page 18 of 25
R0003-08-002089-A Page 97 of 113
R0003-08-002089-A Instrument Setpoint.MethodologyTopical Report 003
AL = Analytical limit.
CU = Trip setpoint uncertainty (the channel uncertainty for the bistable).
Margin = Amount chosen for conservatism. Note that when the trip setpoint is very close to
the system's normal operating point, the margin may be very small, or zero. The,
applied margin must always be greater than or equal to. the as-found tolerance to
guarantee the AV will never exceed the LSSS
AV = NTSP + AFTTOT
Where:
AFTTOT = Total as-found tolerance for the'entire instrument channel
To protect against potential masking of equipment degradation during .periodic surveillance testing; no
margin is included as partof the AV determination and the AFTTOT is applied as a double-sided band
around the.NTSP.
AFTTOT determination includes consideration of all channel AFT uncertainties pertaining to the calibration
being performed. -Therefore, when considering AV, AETTOT is based on;
AFTToT =(AFT,
2
+ AFT
2
2
+....+....+...AFT
2
)
1
/
2
Where:
AFTn as-found tolerance for module "n" (see 4.2.5).
4.2.5 As-Fbund Tolerance
The as-found tolerance (AFT) is the module uncertainty as discovered during module calibration.
Therefore, it does not include uncertainties due to harshenvironment or process measurement, and does
not include primary element uncertainty. AFT includes consideration at a minimum of reference accuracy,
(RA), drift (DR), and as-left tolerance (ALT) uncertainties. The as-left tolerance (ALT) is:also referredto
as "calibration .tolerance" in ANSI/ISA-S67.04.01-2000 (Ref. 6.3.1) or,"setting tolerance" in RIS 2006-17
(Ref. 6.2.4).
The ALT is specified as a double-sided band around the NTSP.'Depending on the condition of the as-
found values for the NTSP, plant specific procedures will direct the operability determination and
Page 19 of 25
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requirements for channel calibration or maintenance. The ALT typically is based on the reference
accuracy of the module being calibrated; however, depending on the particular instrument loop in
question, the limitations of the calibration procedure or need to minimize maintenance time, the
magnitude of the ALT may be specified as a smaller or larger value in the specific calibration procedure.
In this case, if the ALT used in the procedure differs from the reference accuracy specified by the vendor,
the ALT would be included as a separate, explicit term in the setpoint calculation. Thus, in the equation
to determine AFTn, the as-left term is included as a bounding method to account for cases where not all
attributes of the reference accuracy may verified in the particular calibration procedure.
Determination of the AFT may also include measurement and test equipment uncertainty if the equipment
contributes errors greater than one tenth of the measurement uncertainty (refer to Section 3.5). For some
modules, it may be necessary to include additional uncertainties (e.g., TE may be included in the
determination of AFT if a change in the calibration environment occurred).
Therefore:
AFTn =(RA,2 + DRn2 +ALTn2 + MTEn2)2
Where:
AFT = As-found tolerance (any typical module).
n = Module "n".
RA = Device reference accuracy.
DR = Device allowance for drift.
ALT = As-left tolerance.
MTE = Measurement and test equipment effect.
The AFT is evaluated to determine if the instrument needs to be reset after calibration or, if outside of the
tolerance, requires further investigation as to its operability. The as-found readings also provide data for
establishing actual instrument drift. In accordance with RG 1105 (Ref. 6.2.1) and BTP 7-12 (Ref. 6.2.2),
plant specific procedures are required to track, trend and maintain the results of periodic surveillance
testing (i.e., the as-found and as-left values for sensors (as applicable) and modules associated with the
instrument loop) for proper management of instrument uncertainties including drift.
Table 4.2 shows the various conditions to consider during surveillance testing of the instrumentation
channel and are consistent with RIS 2006-17 (Ref: 6.2.4).
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R0003-08-002089-A Instrument Setpoint Methodology Topical Report :003
As-found NTSP within ALT (Region A of Channel is operable, no action required. The results are
Figure 5.1) tracked by plant procedures for historical trending.
As-found NTSP outside of ALT band, but Channel is operable, recalibration is necessary to restore
within AFT band (Region B of Figure 5.1) the NTSP within the ALT.
Increasing process:
outside AFT band (Region D of Figure
5.1); or Channel is inoperable. Recalibration is necessary to
restore the NTSP within the ALT, and evaluation of channel
Decreasinq process: functionality is required.
respect to the AV (NTSP > AV) but
outside AFT band.
Channel is inoperable. Recalibration is necessary to
As-found NTSP non-conservative to the restore NTSP within the ALT, and evaluation of channel
AV (Region C of Figure 5.1) functionality is required to return channel to an operable
status.
The uncertainty for drift is typically obtained for the sensor from manufacturerg in terms of X% URL'over Y
period of time. Since drift is assumed to be random, the guidance provided in ANSI/ISA-RP67.04.02-
2000 (Ref. 6.3.2) applies in calculating the SRSS of the individual drift periods between'calibrations as
shown in the example provided below:
2 2 2 1/2
DRToT =(DRint2 + DR int22+ .. ,..+ DR intn
Where DRTOT is the drift for the total surveillance interval and DRintn is the drift for the time interval
specified by the manufacturer.
For the B&W mPower reactor, the surveillance and calibration intervals are determined as part of the
development of the reference technical specifications. Determination of surveillance and calibration
intervals takes into account the uncertainty due to instrument drift as described in this report such there is
reasonable assurance that the plant protection system instrumentation is performing as expected
between the surveillance intervals. Plant-specific procedures will contain required methods to evaluate
the.historical performance of the drift for each instrument channel and confirm the surveillance and
calibration intervals do not exceed the assumptions in the plant safety analysis. The guidance contained
in Generic Letter 91-04 (Ref. 6.2.5) may be used to evaluate and determine the acceptable surveillance
and calibration intervals for each instrument channel.
Page 21 of 25
R0003-08-002089-A Page 100 of 113 January 201 3, Revision 3
R0003-08-002089-A Instrument Setpoint Methodology Topical Report 003,
4.2.6 Operating Margin
Operating margin (OM) is required between the setpoint and the normal upper or lower limit, as,
applicable, to avoid spurious channel trips during normal operation.
OM = NTSP - NUL (increasing setpoint)
OM = NLL -. NTSP (decreasing setpoint)
Where:
OM = Operating margin.
NUL =.'Normal operating upper limit.
NLL = Normal operating lower limit.
4.2.7 Calcu!ated Functions
Total safety margin (TSM) - (safety margin A x KA),+ (safety margin B x KB) .... + (safety margin n x Kn):
Where:
A, B, ..n are process measurement inputs to the calculated function.
Safety margin is a discretionary-value determined by engineering judgment. Margin is applied to
accommodate normal expected conditions between surveillance intervals (e.g., drift). The applied margin
must ensure that NTSP + AFTTOT does not exceed the allowable value. The minimum margin prevents
expected channel drift from exceeding the AV.
KA, KB,..Kn are constants used-to normalize each parameter to the engineering units of the function
setpoi nts: :
Then:
NTSP =AL (CU +TSM)
,2012 Babcock & Wilcox Nuclear Energy, Inc. All rights reserved.
,.Page 22 of 25
R0003-08-002089-A Page 101 of 113 January,2013, Revision 3
5. SUMMARY/CONCLUSIONS
The results of the calculations are documented in accordance with controlled plant procedures with
adequate detail so that all conclusions are fully understood. The relationships of the various uncertainty
terms, trips, margins, and operating values are diagrammed in Figure 5.1.
Page 23 of 25
R0003-08-002089-A Page 102 ofi 13 January 2013, Revision 3
Plant Safety Analy and Design Basis
SAFETY LIMIT (SL)
ANALYSIS MARGIN,
MODELING ERROF
ANALYTIC LIMIT
(AL)
TRANSIENT RESPONSE,
RESPONSE TIME, ETC.
CHANNEL
UNCERTAINTY (CU)
[Equation 4.2.2]
UMITING TRIP
SETPOINT (LTSP)
[Equation 4.2.3]
MARGIN
(NOTE 1)
[Equation 4.2.3]
7- A!
S (Equation 4.2.4]
,S-LEFT TOTAL AS-FOUND
LERANCE TOLERANCE BAND (AFTTo,)
(ALT) [Equation 4.2.5]
NORMAL
OPERATING MARGIN (OM) -<
(Equation 4.2.6]
NORMAL OPERATING
UPPER LIMIT (NUL)
OPERATING RANGE
REGION C: Channel is inoperable,
SYSTEM SHUTDOWN
PROCESS PARAMETER
NOTES:
Page 24 of 25
6'. REFERENCES
6.1 Code of Federal Regulations
6.1.1 10 CFR 50.36, "Technical Specifications."
6.1.2 10 CFR 50, Appendix A, General Design Criteria (GDC) 13, "Instrumentation and Control."
6.1.3 10 CFR 50, Appendix A, GDC 20 "Protection System Functions."
6.1.4 10 CFR 50, Appendix B, Criterion XI, "Test Control."
6.1.5 10 CFR 50, Appendix B, Criterion XII, "Control of Measuring and Test Equipment."
6.2 U.S. Nuclear Regulatory Guidance
6.2.1 Regulatory Guide 1.105, "Setpoints for Safety Related Instrumentation," Rev. 3, December 1999.
6.2.2 NUREG-0800, Standard Review Plan (SRP), BTP 7-12, "Guidance on Establishing and
Maintaining Instrument. Setpoints," Rev. 5, March 2007.
6.2.3 NUREG-0800, SRP, Appendix 7.1-A, "Acceptance Criteria and Guidelines for Instrumentation
and Control Systems Important to Safety," Rev. 5, March 2007.
6.2.4' RIS 2006-17, "NRC Staff Position on the Requirements of 10 CFR 50.36, 'Technical
Specifications', regarding Limiting Safety System Settings during Periodic Testing and Calibration
of Instrument Channels," Regulatory Issue Summary August 2006.
6.2.5 Generic Letter 91-04, "Guidance on Preparation of a Licensee Amendment Request for
Changes in Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," April 2, 1991.
6.3 U.S. Industry Guidance
6.3.1 ANSI/ISA-S67.04,01-2000, "Setpoints for Nuclear Safety7Related Instrumentation," February
2000 (Equivalent to ANSI/ISA-S67.04, Part 1-1994).
6.3.2 ANSI/ISA-RP67.04.02-2000, "Methodologies for the Determination of Setpoints for Nuclear
Safety-Related Instrumentation," January 2000.
6.3.3 Not used.
Page 25 of 25
Appendix A - Example Setpoint Calculation for a Safety-Related Pressure Channel
Purpose
This section presents an example to demonstrate the applicationof this setpoint methodology for the
determination of the nominal trip setpoint (NTSP), limiting trip setpoint (LTSP) and allowable value (AV)
based on the analytical limit (AL) for a typical safety-related instrument channel. For this example, a
safety-related system pressure channel is used for an increasing process. The safety analysis'
established a safety limit for high system pressure for an increasing process: The establishment of 'trip
setpoints using this methodology will establish the LTSP to verify the limiting safety system setting (LSSS)
is satisfied and ensure the safety limit is protected.
Loop Characteristics and Assumptions
The analytical limit forthis example pressure channel is 1047.0 psig, which is based on the plant safety
analysis. The example pressure channelprotects a high safety-related pressure limit and has a span of
100-1200 psig, with an upper-range limit of 1500 psig. The process conditions are such that the normal
upper limit of the process signal for this loop 'is 892 psig. The simplified loop consists of two modules: the
pressure transmitter and the plant protection layer digital reactor protection system. The pressure
transmitter is located in a mild environment in the reactor'service building and the digital reactor
protection system is located in an environmentally controlled electrical equipment room. The
assumptions for this example instrument loop are:
* The sensor is located in a mild environment not subject to excessive temperature, humidity, pressure
or radiation.
SM&TE errors are bounded by administrative plant procedures to be less than one-quarter of the total
reference accuracy.
" There are no known interdependencies between individual component errors for the loop. All random
uncertainties will be treated as independent.
" There are no known biases associated with this instrument channel.
* The uncertainty associated with process measurement effects (PM) and primary element (PE) effects
are negligible for this channel and will not be considered.
" The inter-connection wiring uncertainty contribution is assumed negligible.
* The uncertainty related to drift is obtained from the manufacturer and is confirmed to be consistent
with the required surveillance interval.
" The reference accuracy for the instrument as provided by vendor is 0.25%,which is less than the
typical as-left tolerance settings in the specific plant calibration procedures. Therefore, the as-left
tolerance of 0.50% will be treated as a separate term (refer to Section 4.2.5) as a bounding case to
minimize maintenance time.
PageA -1 of 4
The example loop diagram for this instrument channel is shown in Figure A.1.
Plant Protection Layer
Digital Reactor Protection
System
Module 1 Module 2
Reactor Service Building Electrical Equipment Room
(mild environment) (mild environment)
Figure A.1: Example Loop Diagram for Safety-Related Instrument Channel
The applicable uncertainties to the pressure transmitter include reference accuracy, drift, power supply
effects, and as-left tolerances resulting from the channel calibration, measurement and test equipment
uncertainties, and environmental effects. All other uncertainty effects are not applicable for this example.
The pressure sensor is located in a mild environment. The terms for RE, TE, SE, and HE are combined
into an overall environmental uncertainty effect (EE) and conservatively set at 2.5% of span. This is
confirmed to be conservative with respect to data reported by the manufacturer.
Sensor Module Uncertainty, el
Equation 4.2.1 is simplified into the following for the transmitter module uncertainty, el:
el= (RA
1
2
+DR
1
2
+PS
1
2
+ALT
1
2
+MTE
1
2
+EE )
1
/
2
Digital Reactor Protection System Module Uncertainty, e2
The digital reactor protection system (RPS) consists generically of an input processing module, logic
processing module, and output processing module. For simplicity, these three sub-systems are
considered as one, 'single integrated system with respect to system uncertainties of the RPS. The system
cannot be calibrated; therefore, the only applicable uncertainty is the overall system reference accuracy
for the digital RPS specified by the vendor. Equation 4.2.1 is simplified into the following for the digital
RPS module uncertainty, e
2
:
e2 =(RA22)/
Calculation of Total Channel Uncertainty, CU
The overall channel uncertainty is determined using equation 4.2.2. Since PM and PE are not applicable,
the total channel uncertainty is determined as follows:
CU =(e
1
2 +e
2
2
)
1
/2
@2012 Babcock & Wilcox Nuclear Energy, Inc. Allrights reserved.
Page A -2 of 4
CU = (RA
1
2+DR
1
2+pS,2+ALT
1
2+MTE
1
+ EE
1
2+RA
2
2)1/2
The parameters for the instrument channel span and range are shown in Table A. 1. The parameters for
RA
1
, DR
1
, PS
1
, and RA
2
are typical values specified by the manufacturer. The uncertainty for MTE
1
is
assumed to be one-quarter of the total reference accuracy of the sensor and is controlled by
administrative procedures. The as-left tolerance is governed by administrative procedures to be no
greater than 0.5% of the span for the instrument channel (see assumptions).
Table A.1: Example Instrument Channel Uncertainties
%span, psig
Sensor (e_)
RAI 0.25% 2.75
DR
1
1.25% 13.75
PS
1
0.05% 0.55
ALT
1
0.50% 5.50
MTE
1
0.06% 0.69
EE, 2.50% '27.50
Digital RPS (eM)
RA
2
0.10% 1.10
The uncertainties from Table A.1 are used to calculate the total channel uncertainty. Using the equation
for CU, the resulting calculation is:
CU - 31.4 psig,'(2.85% span)
LTSP and NTSP are determined as follows for an increasing process using equation 4.2.3. A margin of
,5.0% of span (55 psig) is applied in accordance with Section 4.2.3 to the NTSP, which is based on
engineering judgment to include room for initial assumptions used in the calculation uncertainties and to
account for rounding errors. The LTSP is the LSSS used in the plant technical specifications that protects
the AL to satisfy 10 CFR 50.36. The applied margin must ensure that NTSP + AFTTOT does not exceed
the allowable value. The minimum margin prevents expected channel drift from exceeding the AV.
LTSP = AL - CU = 1047.0 psig - 31.4 psig = 1015.6 psig
NTSP = AL - (CU +"Margin) = 1047.0 - (31.4 psig + 55.0 psig) = 960.6 psig
In determining the allowable value, the as-found tolerance for both modules is considered and equation
4.2.4-is-used to calculate the total as-found value for the instrument channel. Since the digital RPS
cannot be calibrated, the only applicable component for AFT
2
is the reference accuracy.
AFT
1
= (RA
1
2
+ DR
1
2
+ ALT
1
2
+ MTE
1
2
)
11
.
2
AFT
2
=(A22)1/2
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Document No:' ITitle: IRev: I
R0003-08-002089-A Instrument Setpoint Methodology'Topical Report
003
2 2 1/2
AFTTOT = + (AFT
1
+ AFT
2
)
AFTTOT = + (RA
1
2
+ DR
1
2
+ ALT
1
2
+ MTE
1
2
+ RA2+21/2
Substituting the numerical values from Table A. 1, the as-found tolerance value is:
AFTTOT,= 15.1 psig, (1.37% span)
With the value for the total channel as-found tolerance, the allowable value is now calculated using
equation 4.2.4. The channel setpoint is confirmed during periodic surveillance testing to ensure it
remains within the AV to ensure the LTSP remains satisfied.
AV = NTSP AFTT6T = 960.6 psig 15.1 psig = 975.7 psig (-); 945.5 psig (-)
The double-sided band for the AV ensures (1) the SL is protected, and (2) ensures~any equipment
degradation is identified and corrected.
The operating margin is calculated using equation 4.2.6 and ensures that sufficient operating margin
exists to minimize and prevent spurious channel trips should the NTSP drift. Margin is applied to
accommodatenormal expected conditions between surveillance intervals (e.g., drift).
OM = NTSP - NUL (increasing setpoint) = 960.6 psig - 892.0 psig = 68.6, psig.
The relationships between the analytical limit and calculated setpoints for this channel are illustrated in
Figure A.2.
CU = 31.4 psig
LSSS
Margin_>AFTTOT
= 55.0 psig
AL = 1047.0 psig
LTSP= 1015.6psig
AV=975.7 psig
ALT(+),= 966.1 psig
, NTSP = 960.6 psig AL T
5.5 psig AFTToT= 15.1 psig
ALT(-) = 955. 1 psi9
AV=945.5 psig
Operating Margin 68.6
Normal Operating Range
psig
NUL = 892.0 psig
Figure-A.2: Relationships between analytica!. limit and calculated setpoints
@2012 Babcock & Wilcox Nuclear Energy, Inc.-All rights reserved.
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R0003-08-002089-A Page 108 of 113 January 2(013, Revision 3
Appendix B - Definitions
The definitions herein are mostly derived from ANSI/ISA-S67.04.01-2000.(Ref. 6.3.1) and-its references.
Additional definitions for terms specifically used in this methodology are also included.
95/95: A standard statistics term meaning that the results have a 95 percent probability with a 95 percent
confidence level.
Allowable Value: The limiting safety system setting for nuclear reactors is the automatic protective
device value for variables having significant safety functions. It is the value that the trip setpoint or
calibration setting may have when tested periodically, beyond which appropriate action shall be taken.
(ANSI/ISA-S67.04.01-2000). The allowable value defines the maximum and minimum limits of
operability. It is the limiting value of the measured variable at which the trip setpoint or calibration setting
may be found during instrument surveillance to provide adequate assurance that the analytical limit
remains protected.
Analytical Limit: Limit of a measured or calculated variable established by the safety analysis for the
actuation of protective actions. Actuating protective actions at or before the analytical limits ensures that
the safety limit is not exceeded and design conditions of equipment/systems assumed in other analyses
are not exceeded. Analytical limits are developed from event analysis models that consider parameters
such as process delays, rod insertion times, reactivity changes, instrument response times, etc.
As-Found: The condition in which a channel or a portion of channel is found after a period of.operation
and before recalibration (if necessary) (ANSI/ISA-S67.04.01-2000). The as-found value is compared to
the allowable value to determine channel operability.
As-Found Tolerance: The tolerance allowed in accuracy between calibrations of a device or group of
devices. The as-found tolerance establishes the limit of error the defined device can have and still be.
considered functional, beyond which additional evaluation may be required.
As-Left: The condition in which a channel, or portion of a channel, is left after calibration or a surveillance
check.
As-Left Tolerance: The tolerance that establishes the required accuracy band that a device or group of
devices must be calibrated to-and remain within to avoid recalibration when periodically tested. If an
instrument is found to be within the as-left tolerance, no further calibration is required for the instrument
and calculations should assume that an instrument might be left anywhere within this tolerance.
Bias: An uncertainty component that consistently has the same algebraic sign and is expressed as an
estimated limit of error. Bias is defined in ISA-RP67.04.02-2000. Bias terms are the fixed or systematic
uncertainty components within a measurement and are not generally eligible for square root of the sum of
the squares combinations. Sometimes they can be removed, in which case they are not accounted for in
the uncertainty calculation since they can be compensated for in the scaling of the instrumentation. Any
bias effects that cannot be calibrated out are accounted for in the uncertainty calculation.
Page B - 1 of 5
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R0003-08-002089-A Instrument Setpoint Methodology Topical Report 003,
Bistable: A device that changes state when it reaches a preselected signal value.
Channel Uncertainty: The total uncertainty at a designated point in the channel. The channel uncertainty
can be calculated for any point in a channel from module 1' to module 'n', as needed. Depending on the
loop configuration, this uncertainty could apply to actuation or indication.'
Control Loop: A group of interconnected instruments that measures the process variable, compares that
value to a predetermined desired value, and applies to the process variable any change necessary to
make the process value match the desired value.
Drift: An undesired..change in output over a period of time where change is unrelated to the input,
environment, or load (ANSI/ISA-S67.04.01-2000).
External Pressurization Effects: The error of a specific instrument that is associated with ambient
pressure variation.
Harsh Environment: The environment in any plant area that is considered to be harsh as a result of
postulated accidents if the temperature, pressure, relativity humidity, or radiation significantly increases
above the normal conditions.
Humidity Effect: The change in instrument output for a constant input when exposed to varying levels of
ambient humidity.
Hysteresis: The difference between upscale and downscale results in instrument response when
subjected to the same input approached from the opposite direction.
Independent: Independent events, in statistics, are those in which the probability of all occurring at once
is the same as the product of the probabilities of each occurring separately. The uncertainty components
are independent of each otherif their magnitudes or algebraic signs are not significantly correlated. In
setpoint determination, independent uncertainties are those for which the sign or magnitude of one
uncertainty does not affect the sign or magnitude of any other uncertainty.
Indicator Reading Uncertainty: The uncertainty associated with reading an indicator (or recorder) due to
resolution and parallax distortion error. Typically, this is applied to analog indicators. For equipment that
has a digital display or readout, this error is usually considered to be negligible.
Instrument Channel: An arrangement of components and modules required to generate a single
protective action or indication signal when required by a generating plant condition. A channel loses its
identity where single protective action signals are combined.
Insulation Resistance Effect: The change in signal caused by a low insulation resistance of an
interconnecting device or cable. The insulation resistance effect accounts for biases imposed in a loop
due an increase in leakage current between the conductors of instrument signal transmission
components such as signal cables, connectors, splices, terminal block, containment penetration, etc. The
increased leakage is caused by the decrease of component insulation resistance due to extreme changes
2011 Babcock & Wilcox Nuclear Energy, lnc; All rights reserved.
Page B-2 of 5
R0003-08-002089-A Page 110 of 113 January 2013 Revision 3
in environmental .(e.g., elevated temperature and humidity) conditions and is treated as bias. Leakage
currents are negligibly small under normal, non-accident conditions. Therefore, the insulation resistance
effect is only considered credible during an accident environment. This term is used only in determining
instrument channel uncertaintyunder high-energy line break or loss-of-coolant accident conditions.
Additional guidance is provided in ISA-RP67.04.02-2000 for determination of insulation resistance.
Limiting Safety System Setting: The same as allowable value. Limiting safety system settings for
nuclear reactors are settings for automatic protective devices related to those variables having significant
safety functions (ANSI/ISA-S67.04.01-2000). Where a limiting safety system setting is specified for a
variable on which~a safety limit has been placed, the setting must be so chosen that automatic protective
action will correct the abnormal situation before a safety limit is exceeded. The limiting safety system
settings are values defined in the plant Technical Specifications, which determine equipment operability.
Limiting Trip Setpoint: The limiting trip setpoint is the limiting setting for the channel trip setpoint
considering all credible instrument errors associated with the instrument channel such that a trip or
actuation will occur before the analytical limit is reached, regardless of the process or environmental
conditions affecting the instrumentation.
Margin: An additional allowance added to the instrument channel uncertainty to allowfor unknown
uncertainty components. The addition of margin moves the setpoint further away (more conservative)
from the analytical limit or nominal process limits. This is a discretionary value added to protect the
analytical limit, prevent spurious trips, or both, or other reason to add conservatism to the calculation.
Measurement and Test Equipment Uncertainty: Uncertainties of the measurement and test equipment
used during the calibration of a device or multiple devices in an instrument loop.
Mild Environment: An environment that is never more severe than the expected environment during
normal plant operation, including anticipated operational occurrences.
Module: Any assembly of interconnecting components that constitutes an identifiable device, instrument
or piece of equipment. A module can be removed as.a unit and replaced with a spare. It has definable
performance characteristics that permit it to be tested as a unit. A module can be a card, a draw-out
circuit breaker or other subassembly or a larger device, provided it meets the requirements of this
definition.
Module Uncertainty: The total uncertainty attributable to each module that makes up the loop from
module '1' through module 'n'. This uncertainty consists of both random and non-random (bias) terms.
Normal Process Limit: The high or low limit, beyond which the normal process parameter should not
vary. Trip setpoints associated with safety-related functions not having analytical limits established.in the
accident analysis and non-safety related functions might be based on the normal process limit.
Normal Operation Lower Limit: The minimum value the process parameters may attain during normal
operation that, will not result in occurrence of an alarm,, protective trip or abnormal plant condition.
PageB-3of5 K
Document No: Title: Rev-
Normal Operation, Upper Limit: The maximum value the process parameters may attain during normal
operation that, will not result in occurrence of an alarm, protective trip or abnormal plant condition.
Operating Margin: The allowance between the trip setpoint and the normal operation upper or lower limit
that is determined necessary to avoid inadvertent trips from process noise, normal transients and normal
measurement uncertainties. The operating margin encompasses the range of operating conditions to
which a device may be subjected without impairment of designed, operational characteristics.
Overpressu re Effect: The effect of over ranging the pressure sensor of a transmitter.
Power Supply Effect: The uncertainty attributed to variations in normally expected power supply output
voltage..
Primary Element Accuracy: The accuracy of the device installed in the process being measured. It is
the measurement error of a primary element (excluding associated transmitter) that is in contact with a
process resulting in some form of interaction (e.g., this. parameter is generally limited to use in flow
elements).
Process Measurement Effect: The uncertainty that accounts for variations in actual process conditions
(not attributable to the measurement device) that influence the measurement, such as temperature
stratification, density variations, pressure variations, etc.
Radiation Effect: The uncertainty attributed to radiation exposure. Most instruments (excluding post
accident monitoring) are designed to perform their trip functions before harsh radiation conditions are
established; however, the environmental data must be evaluated and it must be shown in the calculation
that the radiation level for trip conditions is below the threshold for radiation induced error. It is a random
error obtained from vendor's functional specifications or qualification data.
Random Variable: A variable whose value at a particular future instant cannot be predicted exactly, but
can only be estimated by a probability distribution function.
Reference Accuracy: A number or quantity that defines the limit that errors will not exceed when the
device is used under reference operating conditions. In this context, error represents the change or
deviation from the ideal value. Reference accuracy includes, as a minimum, repeatability, hysteresis,, and
linearity.
Repeatability: The ability of an instrument to produce exactly the same result every time it is subjected to
the same conditions.
Safety Limit: A limit on an important process variable that is necessary to reasonably protect the integrity
of physical barriers that guard against the uncontrolled release of radioactivity.
Seismic Effect: The uncertainties caused by the vibration associated with an earthquake. This effect is
only considered if the device must function after a seismic event and its value is based on instrument
qualification data by the vendor. This is generally a random independent error.
@2011 Babcock &Wilcox Nuclear Energy,, Inc. All rights reserved.
Page B - 4 of 5
R0003-W002089-A Page 112 of 113 January 2013, Revision 3
Sensor: The portion of a channel that responds to changes in a process variable and converts the
measured variable into an instrument signal (ANSI/ISA-S67.04.01-2006); for example, an electric or
pneumatic output.
SRSS: Square root of the sum of the squares used to combine random uncertainties.
Static Pressure:. The steady-state pressure applied to a device.
Static Pressure Effect: The change in instrument output for a constant input when measuring a
differential pressure and simultaneously exposed to a static pressure.
Span: The algebraic difference between minimum and maximum range value of the instrument in service.
Temperature Effect: The change in instrument output for a constant input when exposed to different
ambient temperatures.
Total Safety Margin: The algebraic sum of the uncertainties, normalized to the appropriate engineering
units, resulting from the combination of two or more signals.
Trip Setpoint: The desired value of the measured variable at which an actuation occurs.
Uncertainty: The amount to which an instrument channel's output is in doubt (or allowance made
therefore) due to possible errors, either random or systematic. The term is generally identified within a
probability and confidence level (ANSI/ISA-S67.04.01-2006) and is generally identified in terms of a
percentage of the span of the instrument.
201 1 Babcock & Wilcox Nuclear Energy, Inc. All rights reserved.
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