ML25237A187
| ML25237A187 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Point Beach, Seabrook, Turkey Point, Duane Arnold  |
| Issue date: | 08/26/2025 |
| From: | Nextera Energy |
| To: | Office of Nuclear Reactor Regulation |
| Marshall, Michael | |
| Shared Package | |
| ML25237A198 | List: |
| References | |
| Download: ML25237A187 (35) | |
Text
NextEra Energy Fleet Pre-Submittal Meeting License Amendment Request for Online Monitoring Open Session August 26, 2025 Non-proprietary information suitable for public disclosure
2 nee_nuclear_fleet_3c Meeting Agenda Introduction
Background
License Amendment Request (LAR) Overview Technical Specification Changes Precedent Schedule Milestones Closing Remarks Questions
3 nee_nuclear_fleet_3c The purpose of this meeting is to discuss a proposed license amendment request (LAR) for the following sites:
- Point Beach Nuclear Plant Units 1 and 2,
- Seabrook Nuclear Plant
- St. Lucie Plant Units 1 and 2
- Turkey Point Nuclear Generating Units 3 and 4 NextEra Energy 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 The proposed license amendment revises Point Beach, St. Lucie, and Turkey Point Technical Specification (TS) 1.1, Use and Application Definitions, and Seabrook TS 1.0 Definitions and adds a new TS Online Monitoring Program (Point Beach TS 5.5.20, Seabrook TS 6.7.6.p, St. Lucie TS 5.5.18, and Turkey Point TS 5.5.18)
Introduction
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- 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
Background
5 nee_nuclear_fleet_3c 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 Background (cont.)
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- In their Safety Evaluation (ML20231A208) the Nuclear Regulatory Commission (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 Background (cont.)
7 nee_nuclear_fleet_3c License Amendment Request (LAR) 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:
- Switch from time-based calibration frequency of pressure, level, and flow transmitters to a condition-based calibration frequency based on OLM results; and
- Assess dynamic failure modes of pressure sensing systems using the noise analysis technique
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- NextEra Energy is developing the OLM implementation process in accordance with OLM implementation methodology described in AMS-TR-0720R2-A for:
- Point Beach Nuclear Plant Units 1 and 2,
- Seabrook Nuclear Plant
- St. Lucie Plant Units 1 and 2
- Turkey Point Nuclear Generating Units 3 and 4 LAR Overview (cont.)
9 nee_nuclear_fleet_3c OLM Implementation Process Development
- Implementation of the OLM program follows the steps identified in AMS-TR-0720R2-A Section 11.1.1.
- AMS Report PTB2401R0, "OLM Amenable Transmitters Report for Point Beach Units 1 and 2
- AMS Report SBR2402R0, "OLM Amenable Transmitters Report for Seabrook Unit 1
- AMS Report STL2402R0, "OLM Amenable Transmitters Report for St. Lucie Units 1 and 2
- AMS Report TKP2401R0, "OLM Amenable Transmitters Report for Turkey Point Units 3 and 4 LAR Overview - OLM Technical Evaluations
10 nee_nuclear_fleet_3c OLM Implementation Process Development (cont.)
- AMS Report PTB2402R0, OLM Analysis Methods and Limits Report for Point Beach Units 1 and 2
- AMS Report SBR2403R0, OLM Analysis Methods and Limits Report for Seabrook Unit 1
- AMS Report STL2403R0, OLM Analysis Methods and Limits Report for St. Lucie Units 1 and 2
- AMS Report TKP2402R0, OLM Analysis Methods and Limits Report for Turkey Point Units 3 and 4 LAR Overview - OLM Technical Evaluations (cont.)
11 nee_nuclear_fleet_3c OLM Program Implementation
- Implementation of the OLM program for NextEra Energy 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 PTB2403R0, OLM Drift Monitoring Program Report for Point Beach Units 1 and 2
- AMS Report SBR2404R0, OLM Drift Monitoring Program Report for Seabrook Unit 1
- AMS Report STL2404R0, OLM Drift Monitoring Program Report for St. Lucie Units 1 and 2
- AMS Report TKP2403R0, OLM Drift Monitoring Program Report for Turkey Point Units 3 and 4 LAR Overview - OLM Technical Evaluations (cont.)
12 nee_nuclear_fleet_3c OLM Program Implementation
- Implementation of the OLM program for NextEra Energy 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 PTB2403R0, OLM Drift Monitoring Program Report for Point Beach Units 1 and 2
- AMS Report SBR2404R0, OLM Drift Monitoring Program Report for Seabrook Unit 1
- AMS Report STL2404R0, OLM Drift Monitoring Program Report for St. Lucie Units 1 and 2
- AMS Report TKP2403R0, OLM Drift Monitoring Program Report for Turkey Point Units 3 and 4 LAR Overview - OLM Technical Evaluations (cont.)
13 nee_nuclear_fleet_3c OLM Noise Analysis Implementation
- Implementation of the OLM program for NextEra Energy 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 PTB2404R0, OLM Noise Analysis Program Report for Point Beach Units 1 and 2
- AMS Report SBR2405R0, OLM Noise Analysis Program Report for Seabrook Unit 1
- AMS Report STL2405R0, OLM Noise Analysis Program Report for St. Lucie Units 1 and 2
- AMS Report TKP2404R0, OLM Noise Analysis Program Report for Turkey Point Units 3 and 4 LAR Overview - OLM Technical Evaluations (cont.)
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- PTB2401R0, SBR2402R0, STL2402R0, and TKP2401R0 address 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.
LAR Overview - OLM Technical Evaluations (cont.)
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- 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.
LAR Overview - OLM Technical Evaluations (cont.)
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- 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.
LAR Overview - OLM Technical Evaluations (cont.)
17 nee_nuclear_fleet_3c The information on these Slides are considered Proprietary and are withheld from this presentation Examples of OLM Amenable Transmitters for NextEra Energy (Using Point Beach 1 and 2 Data)
Examples of OLM Amenable Transmitters for NextEra Energy (Using Seabrook Data)
Examples of OLM Amenable Transmitters for NextEra Energy (Using St. Lucie 1 and 2 Data)
Examples of OLM Amenable Transmitters for NextEra Energy (Using Turkey Point 3 and 4 Data)
LAR Overview - OLM Technical Evaluations (cont.)
a,b,f
18 nee_nuclear_fleet_3c 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 Consistent with approved precedents
- 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 LAR Overview - OLM Technical Evaluations (cont.)
19 nee_nuclear_fleet_3c Application Specific Action Items from AMS OLM TR
- 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
- Criteria for Establishing Transmitter Drift Flagging Limits adopted as described in AMS-TR-0720R2-A ASAI 3 - Response Time Test Elimination Basis LAR Overview - OLM Technical Evaluations (cont.)
20 nee_nuclear_fleet_3c 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
(including Precedent) 5.0 ENVIRONMENTAL EVALUATION
==6.0 REFERENCES
==
LAR Table of Contents
21 nee_nuclear_fleet_3c ATTACHMENTS
- 1.
Point Beach Nuclear Plant Technical Specification Mark-ups
- 2.
Point Beach Nuclear Plant Technical Specification Bases Mark-ups (Information only)
- 3.
Seabrook Nuclear Plant Technical Specification Mark-ups
- 4.
Seabrook Nuclear Plant Technical Specification Bases Mark-ups (Information only)
- 5.
St. Lucie Plant Technical Specification Mark-ups
- 6.
St. Lucie Plant Technical Specification Bases Mark-ups (Information only)
- 7.
Turkey Point Nuclear Generating Technical Specification Mark-ups
- 8.
Turkey Point Nuclear Generating Technical Specification Bases Mark-ups (Information only)
LAR Table of Contents (cont.)
22 nee_nuclear_fleet_3c Proposed CHANNEL CALIBRATION - Point Beach and Turkey Point 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 (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.
Proposed TS Changes - TS Definitions
23 nee_nuclear_fleet_3c Proposed CHANNEL CALIBRATION - Seabrook A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel such that it responds within the required range and accuracy to known values of input. The CHANNEL CALIBRATION shall encompass the entire channel including the sensors and alarm, interlock and/or trip functions (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 from the devices included in the step.
Proposed TS Changes - TS Definitions (cont.)
24 nee_nuclear_fleet_3c Proposed CHANNEL CALIBRATION - St. Lucie 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. 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.
Proposed TS Changes - TS Definitions (cont.)
25 nee_nuclear_fleet_3c Proposed definition of ESF RESPONSE TIME -
Seabrook The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its 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).
Proposed TS Changes - TS Definitions (cont.)
26 nee_nuclear_fleet_3c Proposed definition of ESF RESPONSE TIME - St.
Lucie The ESF 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, or the components have been evaluated in accordance with an NRC approved methodology (including transmitters in the Online Monitoring Program).
Proposed TS Changes - TS Definitions (cont.)
27 nee_nuclear_fleet_3c Proposed definition of RTS RESPONSE TIME -
Seabrook The RTS RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its RTS Trip Setpoint at the channel sensor until loss of stationary gripper coil voltage. 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).
Proposed TS Changes - TS Definitions (cont.)
28 nee_nuclear_fleet_3c Proposed definition of RPS RESPONSE TIME - St.
Lucie The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until electrical power to the CEAs drive mechanism is interrupted. 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, or the components have been evaluated in accordance with an NRC approved methodology (including transmitters in the Online Monitoring Program).
Proposed TS Changes - TS Definitions (cont.)
29 nee_nuclear_fleet_3c Online Monitoring Program
- Point Beach TS 5.5.20
- Seabrook TS 6.7.6.p
- St. Lucie TS 5.5.18
- Turkey Point TS 5.5.18 Proposed TS Changes - Programs
30 nee_nuclear_fleet_3c 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:
- a. Implementation of online monitoring for transmitters that have been evaluated during the plant operating cycle in accordance with an NRC approved methodology.
- 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.
Proposed TS Changes - Programs (cont.)
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- 3) Calibration checks of identified transmitters no later than during the next refueling outage.
- 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 refueling outage.
- c. Performance of calibration checks for transmitters at the specified backstop frequencies.
- d. The provisions of Surveillance Requirement 3.0.3 (4.0.3 for Seabrook) are applicable to the required calibration checks specified in items a.3, b, and c above.
Proposed TS Changes - Programs (cont.)
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- The NextEra Energy license amendment request to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2 is similar to the NRC-approved license amendment request submitted by Southern Nuclear Operating Company for Vogtle Electric Generating Plant Units 1 and 2 (see ML22355A588 and ML23115A149) and Farley Nuclear Plant Units 1 and 2 and Hatch Nuclear Plant Units 1 and 2 (See ML24124A133 and ML24351A080)
Precedents
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- NextEra Energy to submit LAR to NRC by October 24, 2025.
- Request NRC approval within 1-year from submittal.
- 6-month implementation following NRC approval.
Schedule Milestones
Questions
35 nee_nuclear_fleet_3c