Text

Application to Revise Technical Specifications to Use Online Monitoring Methodology – Slides and Affidavit for Pre-Submittal Meeting
	ML23348A357
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	12/14/2023
From:	Couture P; Entergy Operations
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23348A356	List: ML23348A357;
References
	CNRO2023-00023
	Download: ML23348A357 (1)
	v • d • e

Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102

Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213 CNRO2023-00023 December 14, 2023 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Application to Revise Technical Specifications to Use Online Monitoring Methodology - Slides and Affidavit for Pre-Submittal Meeting Arkansas Nuclear One, Units 1 and 2 NRC Docket No. 50-313 and 50-368 Renewed Facility Operating License No. DPR-51 and NPF-6 River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Pursuant to the provisions Section 50.90 of Title 10 Code of Federal Regulations (CFR),

Entergy Operations, Inc.(Entergy) is planning a license amendment to the Arkansas Nuclear One (ANO), Units 1 and 2 (ANO-1 and ANO-2), Grand Gulf Nuclear Station, Unit 1 (GGNS),

River Bend Station, Unit 1 (RBS), and Waterford Steam Electric Station, Unit 3 (WF3). The proposed amendment revises Definitions and adds a new "Online Monitoring Program."

Entergy proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed change is based on the NRC-approved topical report AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters," (Reference).

Entergy has requested a Pre-Submittal meeting the week of January 15, 2024. To support the meeting, Entergy is providing the slides for the meeting in Enclosure 1. Some of the information to be covered during the meeting is considered proprietary to Analysis and Measurement Services Corporation and request it to be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commissions regulations, these slides are provided in Enclosure 2. The proprietary information is identified by text enclosed within double bolded brackets ((Example)).

NOTICE: Enclosure 2 to this letter contains Proprietary Information to be withheld from public disclosure per 10 CFR 2.390. Upon separation from Enclosure 2, this letter is DECONTROLLED.

CNRO2023-00023 Page 2 of 2 To support withholding the slides in Enclosure 2 from public disclosure, Enclosure 3 provides an affidavit, signed by H. M. Hashemian, President and Chief Executive Officer, for Analysis and Measurement Services Corporation (AMS), (AMS Technology Center, 9119 Cross Park Dive, Knoxville, TN 37923), the owner of the information. The affidavit sets forth the basis by which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 FR 2.390 of the Commission's regulations.

This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact me at 601-368-5102.

Respectfully, Phil Couture PC/chm

Enclosures:

1.

Entergy and AMS Slides for Pre-Submittal Meeting - Open Session

2.

Entergy and AMS Slides for Pre-Submittal Meeting - Closed Session (PROPRIETARY)

3.

AMS Affidavit

Reference:

AMS letter to NRC, "Submittal of -A Version of Analysis and Measurement Services Corporation Topical Report AMS-TR-0720R2, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (Docket No. 99902075)," (ML21235A493), dated August 20, 2021 cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - ANO NRC Senior Resident Inspector - GGNS NRC Senior Resident Inspector - RBS NRC Senior Resident Inspector - WF3 NRC Project Manager

- Entergy Fleet NRC Project Manager

- ANO NRC Project Manager

- GGNS NRC Project Manager

- RBS NRC Project Manager

- WF3 Philip Couture Digitally signed by Philip Couture Date: 2023.12.14 11:53:24

-06'00'

CNRO2023-00023 Entergy and AMS Slides for Pre-Submittal Meeting - Open Session (51 pages to follow)

Fleet Pre-Submittal Meeting:

Online Monitoring Implementation based on AMS Topical Report AMS-TR-0720R2-A Open Session January 2024 Arkansas Nuclear One, Unit 1 Arkansas Nuclear One, Unit 2 Grand Gulf Nuclear Station, Unit 1 River Bend Station, Unit 1 Waterford Steam Electric Station, Unit 3

2 Overview

Purpose

Background

License Amendment Request (LAR) Overview

Submittal and Requested Review Schedule

Comments and Discussion

3 Purpose Entergy Operations, Inc., (Entergy) proposes to use an online monitoring (OLM) methodology as the technical basis to switch from a time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.

Discuss the following:

Overview of the LAR contents Entergy schedule for LAR submittal Requested LAR review schedule

4 Background

OLM has been developed and validated for condition monitoring applications in a variety of process and power industries and used to optimize maintenance of transmitters used as sensor input to control and protection systems OLM consists of collecting transmitter data throughout an operating cycle (including startup, shutdown, or other process cycles), analysis of data to detect transmitter drift or degradation in dynamic performance, and identification of transmitters that warrant a calibration check OLM methodology has been used for more than twenty years at the Sizewell B nuclear power plant

5 Background

OLM is a proven methodology based on:

Experience with OLM implementation in nuclear facilities

Comparison between OLM results and manual calibrations

Assessment of transmitter failure modes that can be detected by OLM

Alignment with industry standards and guidelines

6 Background

NRC determined that the Analysis and Measurement Services Corporation (AMS) OLM methodology outlined can be used to provide reasonable assurance that required TS instrument calibration requirements for transmitters will be maintained because it:

Is effective at identifying instrument calibration drift during plant operation

Provides an acceptable means of identifying when manual transmitter calibration using traditional calibration methods are needed

Will maintain an acceptable level of performance that is traceable to calibration prime standards

7 License Amendment Request Overview

NRC approved AMS Topical Report AMS-TR- 0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters in August 2021

This TR was approved for use by licensees to support plant-specific technical specification changes to:

o Switch from time-based calibration frequency of pressure, level, and flow transmitters to a condition-based calibration frequency based on OLM results and o Assess dynamic failure modes of pressure sensing systems using the noise analysis technique

8 License Amendment Request Overview Entergy is developing the OLM implementation process in accordance with OLM implementation methodology described in AMS-TR-0720R2-A for:

Arkansas Nuclear One, Unit 1 Arkansas Nuclear One, Unit 2 Grand Gulf Nuclear Station, Unit 1 River Bend Station, Unit 1 Waterford Steam Electric Station, Unit 3

9 LAR Overview - OLM Technical Evaluations

OLM Implementation Process Development Implementation of the OLM program for Entergy follows AMS-TR-0720R2-A Section 11.1.1 Steps 1-6 identify transmitters in OLM program and determine how to obtain OLM data Documented in AMS Report ANO2302R0, "OLM Amenable Transmitters Report for ANO Unit 1" Documented in AMS Report ANO2307R0, "OLM Amenable Transmitters Report for ANO Unit 2" Documented in AMS Report GGN2302R0, "OLM Amenable Transmitters Report for Grand Gulf" Documented in AMS Report RBD2302R0, "OLM Amenable Transmitters Report for River Bend" Documented in AMS Report WAT2302R0, "OLM Amenable Transmitters Report for Waterford"

10 LAR Overview - OLM Technical Evaluations

OLM Implementation Process Development Steps 7-8 address calculation of OLM limits and establish methods of OLM data analysis AMS Report ANO2303R0, " OLM Analysis Methods and Limits Report for ANO Unit 1" AMS Report ANO2308R0, "OLM Analysis Methods and Limits for Report ANO Unit 2" AMS Report GGN2303R0, "OLM Analysis Methods and Limits Report for Grand Gulf" AMS Report RBD2303R0, "OLM Analysis Methods and Limits Report for River Bend" AMS Report WAT2303R0, "OLM Analysis Methods and Limits Report for Waterford"

11 LAR Overview - OLM Technical Evaluations

OLM Program Implementation Implementation of the OLM program for Entergy follows AMS-TR-0720R2-A Section 11.1.2 A mapping AMS-TR-0720R2-A Section 11.1.2 and LAR sections where items are addressed is provided Implementation of these steps is performed using AMS software programs AMS Report ANO2304R0, "OLM Drift Monitoring Program Report for ANO Unit 1" AMS Report ANO2309R0, "OLM Drift Monitoring Program Report for ANO Unit 2" AMS Report GGN2304R0, "OLM Drift Monitoring Program Report for Grand Gulf" AMS Report RBD2304R0, "OLM Drift Monitoring Program Report for River Bend" AMS Report WAT2304R0, "OLM Drift Monitoring Program Report for Waterford"

12 LAR Overview - OLM Technical Evaluations

OLM Noise Analysis Implementation Implementation of the OLM program for Entergy follows AMS-TR-0720R2-A Section 11.3.3 A mapping AMS-TR-0720R2-A Section 11.3.3 and LAR sections where items are addressed is provided Implementation of these steps is performed using the qualified noise data acquisition equipment and software programs developed by AMS AMS Report ANO2305R0, "OLM Noise Analysis Program Report for ANO Unit 1" AMS Report ANO2310R0, "OLM Noise Analysis Program Report for ANO Unit 2" AMS Report GGN2305R0, "OLM Noise Analysis Program Report for Grand Gulf" AMS Report RBD2305R0, "OLM Noise Analysis Program Report for River Bend" AMS Report WAT2305R0, "OLM Noise Analysis Program Report for Waterford"

13 LAR Overview - OLM Technical Evaluations

ANO2302R0, ANO2307R0, GGN2302R0, RBS2302R0, WAT2302R0 addresses steps 1-6, from AMS-TR-0720R2-A Section 11.1.1 to establish amenable transmitters and data collection Step 1. Determine if Transmitters are Amenable to OLM AMS-TR-0720R2-A Chapter 12 includes Table 12.4 that lists the nuclear grade transmitter models that are amenable to OLM. Any transmitter model that is not listed in this table should only be added to the OLM program if it can be shown by similarity analysis that its failure modes are the same as the listed transmitter models or otherwise detectable by OLM.

14 LAR Overview - OLM Technical Evaluations Step 2. List Transmitters in Each Redundant Group This step establishes how to group the transmitters and evaluates the redundancy of each group.

Step 3. Determine if OLM Data Covers Applicable Setpoints This step evaluates the OLM data for each group to determine if it covers applicable setpoints as described in AMS-TR-0720R2-A Chapter 14.

Step 4. Calculate Backstops A backstop, as described in AMS-TR-0720R2-A Chapter 13, must be established for each group of redundant transmitters amenable to OLM as a defense against common mode drift. The backstop identifies the maximum period between calibrations without calibrating at least one transmitter in a redundant group.

15 LAR Overview - OLM Technical Evaluations Step 5. Establish Method of Data Acquisition OLM data is normally available in the plant computer or an associated data historian. If data is not available from the plant computer or historian, a custom data acquisition system including hardware and software must be employed to acquire the data.

Step 6. Specify Data Collection Duration and Sampling Rate OLM data must be collected during startup, normal operation, and shutdown periods at the highest sampling rate by which the plant computer takes data. AMS-TR-0720R2-A Chapter 15 describes a process to determine the minimum sampling rate for OLM data acquisition to monitor for transmitter drift. AMS-TR-0720R2-A Chapter 8 describes a process to help determine the optimal sampling rate and minimum duration of OLM data collection.

16 LAR Overview - OLM Technical Evaluations a,b,f The information on these Slides are considered Proprietary and are withheld from this presentation Examples of OLM Amenable Transmitters for Entergy (Using ANO1 Data)

Examples of OLM Amenable Transmitters for Entergy (Using ANO2 Data)

Examples of OLM Amenable Transmitters for Entergy (Using GGNS Data)

Examples of OLM Amenable Transmitters for Entergy (Using RBS Data)

Examples of OLM Amenable Transmitters for Entergy (Using WF3 Data)

17

Application Specific Action Items from AMS OLM TR ASAI 1 - Evaluation and Proposed Mark-up of Existing Plant Technical Specifications TS changes provided in LAR are an adaptation from illustrative changes presented in AMS-TR-0720R2-A Simplify the required plant-specific changes with no required changes to Channel Calibration and Response Time Surveillance Requirements Online Monitoring Program description reorganized to better align with OLM implementation activities LAR Overview - OLM Technical Evaluations

18 ASAI 2 - Identification of Calibration Error Source Calibration error for OLM signal path evaluated as part of the calculation of OLM limits as described in AMS-TR-0720R2-A ASAI 3 - Response Time Test Elimination Basis OLM noise analysis methods adopted as basis for Response Time Test Elimination as prescribed in AMS-TR-0720R2-A ASAI 4 - Use of Calibration Surveillance Interval Backstop Calibration surveillance interval backstop methods adopted as described in AMS-TR-0720R2-A LAR Overview - OLM Technical Evaluations

19 ASAI 5 - Use of Criteria other than in AMS OLM TR for Establishing Transmitter Drift Flagging Limit Criteria for Establishing Transmitter Drift Flagging Limits adopted as described in AMS-TR-0720R2-A LAR Overview - OLM Technical Evaluations

20 LAR Table of Contents 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

2.1 Background

2.2 System Design and Operation 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

3.0 TECHNICAL EVALUATION

3.1 OLM Implementation Process Development 3.2 OLM Program Implementation 3.3 OLM Noise Analysis Implementation 3.4 Application Specific Action Items from AMS OLM TR

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL EVALUATION

6.0 REFERENCES

21 LAR Table of Contents 7.0 ATTACHMENTS

1. Technical Specification Mark-ups

- ANO-1

2. Technical Specification Mark-ups

- ANO-2

3. Technical Specification Mark-ups

- GGNS

4. Technical Specification Mark-ups

- RBS

5. Technical Specification Mark-ups

- Waterford-3

6. Technical Specification Clean Typed

- ANO-1

7. Technical Specification Clean Typed

- ANO-2

8. Technical Specification Clean Typed

- GGNS

10. Technical Specification Clean Typed

- Waterford-3

11. Technical Specification Bases Mark-ups - ANO-1 (Information only)

12. Technical Specification Bases Mark-ups - ANO-2 (Information only)

13. Technical Specification Bases Mark-ups - GGNS (Information only)

14. Technical Specification Bases Mark-ups - RBS (Information only)

15. Technical Specification Bases Mark-ups - Waterford-3 (Information only)

22 Proposed TS Changes - TS Definitions - ANO-1 ANO-1 CHANNEL CALIBRATION

23 Proposed TS Changes - TS Definitions - ANO-1 Proposed CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel.

24 Proposed TS Changes - TS Definitions - ANO-2 ANO-2 1.9 CHANNEL CALIBRATION 1.23 REACTOR TRIP SYSTEM RESPONSE TIME 1.24 ENGINEERED SAFETY FEATURE RESPONSE TIME

25 Proposed TS Changes - TS Definitions - ANO-2 Proposed TS 1.9 CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

26 Proposed TS Changes - TS Definitions - ANO-2 Proposed TS 1.23 REACTOR TRIP SYSTEM RESPONSE TIME The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power is interrupted to the CEA drive mechanism. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

27 Proposed TS Changes - TS Definitions - ANO-2 Proposed TS 1.24 ENGINEERED SAFETY FEATURE RESPONSE TIME The ENGINEERED SAFETY FEATURE RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

28 Proposed TS Changes - TS Definitions - Waterford-3 Waterford-3 1.4 CHANNEL CALIBRATION 1.12 ENGINEERED SAFETY FEATURE RESPONSE TIME 1.25 REACTOR TRIP SYSTEM RESPONSE TIME

29 Proposed TS Changes - TS Definitions - Waterford-3 Proposed TS 1.4 CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel (excluding transmitters in the Online Monitoring Program) required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

30 Proposed TS Changes - TS Definitions - Waterford-3 Proposed TS 1.12 ENGINEERED SAFETY FEATURES RESPONSE TIME The ENGINEERED SAFETY FEATURES RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

The change to ENGINEERED SAFETY FEATURES RESPONSE TIME is on TS page 1-3. An additional minor editorial change in being made just below this definition. An errant '#' mark is being removed. This is noted on the markup page.

31 Proposed TS Changes - TS Definitions - Waterford-3 Proposed TS 1.25 REACTOR TRIP SYSTEM RESPONSE TIME The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power to the CEA drive mechanism is interrupted. The response time may be measured by any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

32 Proposed TS Changes - TS Definitions - GGNS GGNS CHANNEL CALIBRATION EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME END OF CYCLE RECIRCULATION PUMP TRIP (EOC RPT) SYSTEM RESPONSE TIME ISOLATION SYSTEM RESPONSE TIME REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME

33 Proposed TS Changes - TS Definitions - GGNS Proposed CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step, so that the entire channel is calibrated.

34 Proposed TS Changes - TS Definitions - GGNS Proposed EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

35 Proposed TS Changes - TS Definitions - GGNS Proposed END OF CYCLE RECIRCULATION PUMP TRIP (EOC-RPT) SYSTEM RESPONSE TIME The EOC-RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured, except for the breaker arc suppression time, which is not measured but is validated to conform to the manufacturer's design value. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

36 Proposed TS Changes - TS Definitions - GGNS Proposed ISOLATION SYSTEM RESPONSE TIME The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

37 Proposed TS Changes - TS Definitions - GGNS Proposed REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME - The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

38 Proposed TS Changes - TS Definitions - RBS RBS CHANNEL CALIBRATION EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME END OF CYCLE RECIRCULATION PUMP TRIP (EOC RPT) SYSTEM RESPONSE TIME ISOLATION SYSTEM RESPONSE TIME REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME TURBINE BYPASS SYSTEM RESPONSE TIME

39 Proposed TS Changes - TS Definitions - RBS Proposed CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step, so that the entire channel is calibrated.

40 Proposed TS Changes - TS Definitions - RBS Proposed EMERGENCY CORE COOLING SYSTEM (ECCS) RESPONSE TIME The ECCS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ECCS initiation setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

41 Proposed TS Changes - TS Definitions - RBS Proposed END OF CYCLE RECIRCULATION PUMP TRIP (EOC RPT) SYSTEM RESPONSE TIME The EOC-RPT SYSTEM RESPONSE TIME shall be that time interval from initial movement of the associated turbine stop valve or the turbine control valve to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

42 Proposed TS Changes - TS Definitions - RBS Proposed ISOLATION SYSTEM RESPONSE TIME The ISOLATION SYSTEM RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

43 Proposed TS Changes - TS Definitions - RBS Proposed REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

44 Proposed TS Changes - TS Definitions - RBS Proposed TURBINE BYPASS SYSTEM RESPONSE TIME The TURBINE BYPASS SYSTEM RESPONSE TIME consists of two components:

a.

The time from initial movement of the main turbine stop valve or control valve until 80% of the turbine bypass capacity is established; and

b.

The time from initial movement of the main turbine stop valve or control valve until initial movement of the turbine bypass valve.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for transmitters in the Online Monitoring Program provided that the methodology for verification has been previously reviewed and approved by the NRC.

45 Proposed TS Changes - Programs Online Monitoring Program

ANO 1 TS 5.5.18

ANO 2 TS 6.5.20

GGNS TS 5.5.14

RBS TS 5.5.16

Waterford-3 TS 6.5.20

46 Proposed TS Changes - Programs Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters" (proprietary version). The program shall include the following elements:

47 Proposed TS Changes - Programs

a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.

1) Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration

check,

2) Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance,

3) Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and

48 Proposed TS Changes - Programs

4) Documentation of the results of the online monitoring data analysis.

b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.

c. Performance of calibration checks for transmitters at the specified backstop frequencies.

d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

49 Submittal and Requested Review Schedule Entergy Planned Submittal - January 2024 Requested Approval

- February 2025

50 Comments and Discussion

CNRO2023-00023 Entergy and AMS Slides for Pre-Submittal Meeting - Closed Session (PROPRIETARY)

(8 pages to follow)

NOTICE: Enclosure 2 to this letter contains Proprietary Information to be withheld from public disclosure per 10 CFR 2.390. Upon separation from Enclosure 2, this letter is DECONTROLLED.

CNRO2023-00023 AMS Affidavit (3 pages to follow)

STATE OF TENNESSEE COUNTY OF KNOX NUCLEI-\\//

ANALYSIS AND MEASUREMENT SERVICES CORPORATION AMS Technology Center 9119 Cross Park Drive Knoxville, TN 37923 USA Phone (865) 691-1756

Fax (865) 691-9344 Email: info@ams-corp.com

www.ams-corp.com November 29, 2023 AFFIDAVIT

1. I, H.M. Hashemian, am an officer of Analysis and Measurement Services Corporation (AMS) and familiar with the criteria that is applied to determine whether certain AMS information is proprietary. I am familiar with the policies established by AMS to ensure the proper application of these criteria.

2.

In accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding,"

AMS requests withholding from public disclosure of the documents listed in Table 1, which is attached to this affidavit. The documents contain research, development, application, product design details, and process qualification information related to the AMS online monitoring methodology. AMS has expended a significant amount of money and effort involving numerous contractors over more than 30 years to develop this product.

3. As required by 10 CFR 2.390, AMS has included in attached Table 1 the following information:

Identity of the document or part sought to be withheld; Declaration of the basis for proposing the information be withheld, encompassing considerations set forth in § 2.390(a);

Specific statement of the harm that would result if the information sought to be withheld is disclosed to the public; and Locations in the documents of all information sought to be withheld.

4. As required in § 2.390(b)(4), AMS wishes to note that the request for withholding from public disclosure applies to pages that contain commercially sensitive information that AMS normally discloses only under a Non-Disclosure Agreement (NOA). This commercially sensitive information is not available in public sources and is the type of information customarily held in confidence by AMS and our competitors. Some examples of categories of information which fit into the definition of proprietary information are:

a) Information which discloses process, method, or apparatus, including supporting data and analyses, where prevention of its use by AMS's competitors without license or contract from AMS constitutes a competitive, economic advantage over other companies in the industry.

November 2023

b) Information, which if used by competitors, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, application, installation, assurance of quality, or licensing of a similar-product.

c)

Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of AMS, its customers, its partners, or its suppliers.

d) Information which reveals aspects of past, present, or future AMS customer-funded development plans or programs, of potential commercial value to AMS.

e) Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

f)

Information obtained through AMS actions which could reveal additional insights into nuclear equipment qualification processes, customer applications, and regulatory proceedings, and which are not otherwise readily obtainable by a competitor.

5. AMS is transmitting this information to NRC in confidence.

6.

As noted in attached Table 1, release of this information in a public forum could cause harm to AMS by revealing trade secrets and/or commercially sensitive design and operational details and technical processes related to designing, building, and/or implementing the AMS online monitoring methodology.

7. As AMS President and Chief Executive Officer, I am authorized to apply for its withholding on behalf of AMS.

8. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

Sworn to and subscribed before me H.M. Hashemian, Ph.D.

President and Chief Executive Officer Analysis and Measurement Services Corporation Knoxville, Tennessee, 37923 November 1 2023 November 2023

Table 1. Documents requested for withholding from public disclosure November 29, 2023 Basis for proposing the Part of document information be Specific statement of the harm that would Document Title sought to be

withheld, result if the information sought to be withheld from encompassing withheld is disclosed to the public public disclosure considerations set forth in§ 2.390(a)

AMS would be harmed by disclosure of the identified commercially sensitive information, which is of value to a competitor because it would enable competitors to make direct comparisons between aspects of their on line monitoring (OLM) technology and the corresponding details for the AMS OLM methodology.

AMS would be harmed by disclosure of its proprietary technical processes for the development and implementation of its Presentation OLM methodology. These processes underpin the integrity of measuring and test Package:

equipment used to implement its OLM Entergy Fleet Pre-All slides in Trade secrets methodology, which are an important Submittal Meeting:

presentation and/ or competitive advantage for AMS.

Online Monitoring package in their commercial AMS would be harmed by disclosure of Implementation entirety.

information as commercially sensitive details of how the based on AMS Topical Report (see Note 1) per§ 2.390(a)(4) OLM methodology is implemented. This AMS-TR-0720R2-would be of value to a competitor in A Closed Session understanding specific competitive design and operational characteristics of the OLM methodology.

AMS would be harmed by disclosure of the identified commercially sensitive information, which is of value to a competitor because it defines the specific methods used by AMS to qualify and validate the online monitoring methodology, which would enable competitors to duplicate the process without having to perform the associated research and development.

Notes:

(1)

As required in NRC Regulatory Information Summary (RIS) 2014-01, documents containing proprietary information are marked with the word "Proprietary" at the top of the first page of the document and at the top of each page containing such information.