RA-24-0273, License Amendment Request to Revise Technical Specifications to Use Online Monitoring Methodology

License Amendment Request to Revise Technical Specifications to Use Online Monitoring Methodology

ML25282A076
Person / Time
Site:	Mcguire, Catawba, Brunswick, Robinson, McGuire
Issue date:	10/09/2025
From:	Gibby S Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RA-24-0273
Download: ML25282A076 (1)

Text

Shawn K. Gibby Vice President Nuclear Engineering Duke Energy 13225 Hagers Ferry Rd., MG011E Huntersville, NC 28078 704-519-5138 Shawn.Gibby@duke-energy.com 10 CFR 50.90 October 9, 2025 Serial: RA-24-0273 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 / RENEWED LICENSE NOS. DPR-71 and DPR-62 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 / RENEWED LICENSE NOS. NPF-35 AND NPF-52 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370 / RENEWED LICENSE NOS. NPF-9 AND NPF-17 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23

Subject:

License Amendment Request to Revise Technical Specifications to Use Online Monitoring Methodology In accordance with the provisions of 10 CFR 50.90, Duke Energy Carolinas, LLC and Duke Energy Progress, LLC (collectively referred to as Duke Energy), is submitting a request for an amendment to the Technical Specifications (TS) for Brunswick Steam Electric Plant, Units 1 and 2 (BSEP), Catawba Nuclear Station, Units 1 and 2 (CNS), McGuire Nuclear Station, Units 1 and 2 (MNS), and H. B. Robinson Steam Electric Plant, Unit 2 (HBRSEP).

The proposed amendment revises BSEP, CNS, MNS, and HBRSEP TS 1.1, Use and Application Definitions, and adds new BSEP TS 5.5.16, CNS TS 5.5.18, MNS TS 5.5.19, and HBRSEP TS 5.5.19 Online Monitoring Program. Duke Energy proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for 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.

Duke Energy requests approval of the proposed amendment within 6 months of acceptance of this submittal. The proposed changes would be implemented within 6 months after issuance of the amendments.

U.S. Nuclear Regulatory Commission Page 2 of 2 Serial: RA-24-0273 In accordance with 10 CFR 50.91, a copy of this application, with enclosure, is being provided to the designated North Carolina and South Carolina Officials.

This letter contains no regulatory commitments.

Please refer any questions regarding this submittal to Ryan Treadway, Director - Nuclear Fleet Licensing, at (980) 373-5873.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 9, 2025.

Sincerely, Shawn Gibby Vice President - Nuclear Engineering

Enclosure:

Evaluation of the Proposed Change Attachments to the Enclosure 1.

Brunswick Steam Electric Plant Unit 1 Technical Specification Mark-ups 2.

Brunswick Steam Electric Plant Unit 1 Technical Specification Bases Mark-ups (Information only) 3.

Brunswick Steam Electric Plant Unit 2 Technical Specification Mark-ups 4.

Brunswick Steam Electric Plant Unit 2 Technical Specification Bases Mark-ups (Information only) 5.

Catawba Nuclear Station Technical Specification Mark-ups 6.

Catawba Nuclear Station Technical Specification Bases Mark-ups (Information only) 7.

McGuire Nuclear Station Technical Specification Mark-ups 8.

McGuire Nuclear Station Technical Specification Bases Mark-ups (Information only) 9.

H.B. Robinson Steam Electric Plant Unit No. 2 Technical Specification Mark-ups

10. H.B. Robinson Steam Electric Plant Unit No. 2 Technical Specification Bases Mark-ups (Information only) cc: USNRC Region II Regional Administrator USNRC NRR Project Manager for BSEP USNRC NRR Project Manager for CNS USNRC NRR Project Manager for MNS USNRC NRR Project Manager for HBRSEP USNRC NRR Project Manager for Duke Energy Nuclear Fleet USNRC Senior Resident Inspector for BSEP USNRC Senior Resident Inspector for CNS USNRC Senior Resident Inspector for MNS USNRC Senior Resident Inspector for HBRSEP L. Brayboy, Radioactive Materials Branch Manager - NC DHHS L. Garner, Manager - Radioactive & Infectious Waste Section - SC DES S. Jenkins, Director - Radiological Health Program - SC DES N. Gauthier, Manager - Nuclear Response Section - SC DES A. Wilson, Attorney General SC Chair - North Carolina Utilities Commission

U.S. Nuclear Regulatory Commission Serial: RA-24-0273 Enclosure ENCLOSURE EVALUATION OF THE PROPOSED CHANGE 125 PAGES AFTER THIS COVER

ENCLOSURE Evaluation of Proposed Change

1.

SUMMARY

DESCRIPTION

2.

DETAILED DESCRIPTION

2.1 Background

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

3. 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. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination Analysis 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1.

Brunswick Steam Electric Plant Unit 1 Technical Specification Mark-ups

2.

Brunswick Steam Electric Plant Unit 1 Technical Specification Bases Mark-ups (Information only)

3.

Brunswick Steam Electric Plant Unit 2 Technical Specification Mark-ups

4.

Brunswick Steam Electric Plant Unit 2 Technical Specification Bases Mark-ups (Information only)

5.

Catawba Nuclear Station Technical Specification Mark-ups

6.

Catawba Nuclear Station Technical Specification Bases Mark-ups (Information only)

7.

McGuire Nuclear Station Technical Specification Mark-ups

8.

McGuire Nuclear Station Technical Specification Bases Mark-ups (Information only)

9.

H.B. Robinson Steam Electric Plant Unit No. 2 Technical Specification Mark-ups

10. H.B. Robinson Steam Electric Plant Unit No. 2 Technical Specification Bases Mark-ups (Information only)

Enclosure to RA-24-0273 Evaluation of Proposed Change E-1 1

SUMMARY

DESCRIPTION Pursuant to the provisions Section 50.90 of Title 10 Code of Federal Regulations (CFR), Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC (Duke Energy) hereby requests a license amendment to the Brunswick Steam Electric Plant (BSEP), Units 1 and 2, Catawba Nuclear Station (CNS), Units 1 and 2, McGuire Nuclear Station (MNS), Units 1 and 2, and H.B.

Robinson Steam Electric Plant Unit No. 2 (HBRSEP) operating licenses. The proposed amendment revises Definitions and adds a new Online Monitoring Program. Duke Energy proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies based on OLM results for pressure, level, and flow transmitters that will reside within the OLM Program.

2 DETAILED DESCRIPTION

2.1 Background

OLM technologies have been developed and validated for condition monitoring applications in a variety of process and power industries. This application of OLM is used to optimize maintenance of instrumentation and control (I&C) systems including online drift monitoring and assessment of dynamic failure modes of transmitters. Analysis and Measurement Services (AMS) Topical Report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (References 1 and 2), focused on the application of OLM for monitoring drift of pressure, level, and flow transmitters in nuclear power plants. The TR addressed the following topics:

Advances in OLM implementation technology to extend transmitter calibration intervals Experience with OLM implementation in nuclear facilities Comparison between OLM results and manual calibrations Transmitter failure modes that can be detected by OLM Related regulatory requirements and industry standards and guidelines Procedures for implementation of OLM methodology Changes that must be made to existing technical specifications to adopt OLM AMS-TR-0720R2-A provided the NRC with the information needed to approve the AMS OLM methodology for implementation in nuclear power plants. The TR is intended to be used by licensees to support plant-specific technical specification changes to switch from time-based calibration frequencies of pressure, level, and flow transmitters to condition-based calibration frequencies based on OLM results and to develop procedures to assess dynamic failure modes of pressure sensing systems using the noise analysis technique.

The NRC staff determined that the methodology outlined in the AMS OLM TR for applying OLM techniques to pressure, level, and flow transmitters can be used to provide reasonable assurance that required Technical Specifications (TS) instrument calibration requirements for transmitters will be maintained. This determination was based on the NRC staff finding that OLM techniques: a) are effective at identifying instrument calibration drift during plant operation, b) provide an acceptable means of identifying when manual transmitter calibration using traditional calibration methods are needed, and c) will maintain an acceptable level of performance that is traceable to calibration prime standards.

Enclosure to RA-24-0273 Evaluation of Proposed Change E-2 The NRC staff found that implementation of an OLM program in accordance with the approved AMS OLM TR provides an acceptable alternative to periodic manual calibration surveillance requirements upon implementation of the application-specific action items (ASAI) in Section 4.0 of its safety evaluation. The ASAIs are addressed in Section 3.4 below.

2.2 System Design and Operation 2.2.1 Brunswick Steam Electric Plant Units 1 and 2 The transmitters to be included in the Online Monitoring Program provide input to the Reactor Protection Systems (RPS) and various engineered safety features and are used for Post Accident Monitoring (PAM), the remote shutdown monitoring, and Reactor Coolant System (RCS) Leakage Detection Instrumentation.

The RPS initiates a reactor scram when one or more monitored parameters exceed their specified limits, to preserve the integrity of the fuel cladding and the reactor coolant pressure boundary and minimize the energy that must be absorbed following design basis accidents (DBAs). The RPS and related instrumentation are identified in TS Table 3.3.1.1-1, Reactor Protection System Instrumentation.

The feedwater and main turbine high water level trip instrumentation is designed to detect a potential failure of the Feedwater Level Control System that causes excessive feedwater flow.

With excessive feedwater flow, the water level in the reactor vessel rises toward the high water level setting causing the trip of the two feedwater pump turbines and the main turbine. The feedwater and main turbine high water level trip instrumentation is addressed in TS 3.3.2.2, Feedwater and Main Turbine High Water Level Trip Instrumentation.

The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for DBAs. The PAM instrumentation is identified in TS Table 3.3.3.1-1, Post Accident Monitoring Instrumentation.

Remote shutdown monitoring instrumentation provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. Remote shutdown monitoring instrumentation is addressed in TS 3.3.3.2, Remote Shutdown Monitoring Instrumentation.

The Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) System initiates an RPT, adding negative reactivity, following events in which a scram does not (but should) occur, to lessen the effects of an ATWS event. The ATWS-RPT and related instrumentation is addressed in TS 3.3.4.1, Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation.

The Emergency Core Cooling System (ECCS) instrumentation initiates appropriate responses from the systems to ensure that fuel is adequately cooled in the event of a DBA or transient.

The ECCS instrumentation is identified in TS Table 3.3.5.1-1, Emergency Core Cooling System Instrumentation.

The Reactor Core Isolation Cooling (RCIC) System instrumentation initiates actions to ensure adequate core cooling when the reactor vessel is isolated from its primary heat sink (the main condenser) and normal coolant makeup flow from the Reactor Feedwater System is insufficient or unavailable, such that RCIC System initiation occurs and maintains sufficient reactor water level such that initiation of the low pressure ECCS pumps does not occur. The RCIC System

Enclosure to RA-24-0273 Evaluation of Proposed Change E-3 instrumentation is identified in TS Table 3.3.5.2-1, Reactor Core Isolation Cooling System Instrumentation.

The primary containment isolation instrumentation automatically initiates closure of appropriate primary containment isolation valves (PCIVs). The function of the PCIVs, in combination with other accident mitigation systems, is to limit fission product release during and following postulated DBAs. Primary containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a DBA. The Primary Containment Isolation instrumentation is identified in TS Table 3.3.6.1-1, Primary Containment Isolation Instrumentation.

The secondary containment isolation instrumentation automatically initiates closure of appropriate secondary containment isolation dampers (SCIDs) and starts the Standby Gas Treatment (SGT) System. The function of these systems, in combination with other accident mitigation systems, is to limit fission product release during and following postulated DBAs.

Secondary containment isolation and establishment of vacuum with the SGT System ensures that fission products that leak from primary containment following a DBA, or are released outside primary containment, or are released during certain operations when primary containment is not required to be operable are maintained within applicable limits. The Secondary Containment Isolation Instrumentation is identified in TS Table 3.3.6.2-1, Secondary Containment Isolation instrumentation.

The RCS Leakage Detection instrumentation is provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitative measurement of leakage rates. The drywell floor drain sump flow monitoring system monitors the leakage collected in the floor drain sump. The RCS Leakage Detection Instrumentation is addressed in TS 3.4.5, RCS Leakage Detection Instrumentation.

The ECCS is designed, in conjunction with the primary and secondary containment, to limit the release of radioactive materials to the environment following a DBA. The ECCS instrumentation is addressed in TS 3.5.1, ECCS - Operating.

The RPS, various engineered safety features, PAM, remote shutdown monitoring, and RCS Leakage Detection transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection will be provided in AMS Report BRU2501R0, Amenable Transmitters Report for AMS Report Brunswick Units 1 and 2.

Switching from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies will not create any physical changes to the plant. The changes will not impact how the plant operates. Duke Energy will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.

2.2.2 Catawba Nuclear Station Units 1 and 2 The transmitters to be included in the Online Monitoring Program provide input to the Reactor Trip Systems (RTS) and Engineered Safety Feature Actuation Systems (ESFAS) and are used for Post Accident Monitoring (PAM), the Remote Shutdown Systems (RSS), Reactor Coolant System (RCS) Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits, Low Temperature Overpressure Protection (LTOP) System, and RCS Leakage Detection Instrumentation.

Enclosure to RA-24-0273 Evaluation of Proposed Change E-4 The RTS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and RCS pressure boundary during anticipated operational occurrences and to assist the Engineered Safety Features Systems in mitigating accidents. The RTS and related instrumentation are identified in TS Table 3.3.1-1, Reactor Trip System Instrumentation.

The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the RCS pressure boundary, and to mitigate accidents. The ESFAS-related instrumentation is identified in TS Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation.

The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents. The PAM instrumentation is identified in TS Table 3.3.3-1, Post Accident Monitoring Instrumentation.

The RSS provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. The RSS instrumentation is identified in TS Table 3.3.4-1, Remote Shutdown System Instrumentation and Controls.

The DNB limits address requirements for maintaining RCS pressure, temperature, and flow rate within limits assumed in the safety analyses. The safety analyses of normal operating conditions and anticipated operational occurrences assume initial conditions within the normal steady state envelope. The limits placed on RCS pressure, temperature, and flow rate ensure that the minimum departure from nucleate boiling ratio will be met for each of the transients analyzed.

The RCS pressure limit is consistent with operation within the nominal operational envelope.

Pressurizer pressure indications are averaged to produce a value for comparison to the limit. A lower pressure will cause the reactor core to approach DNB limits. Flow rate indications are averaged within a loop and then summed among the four loops to come up with a value for comparison to the limit. A lower RCS flow will cause the core to approach DNB limits.

The LTOP System controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary is not compromised by violating the pressure and temperature limits.

TS 3.4.12, Low Temperature Overpressure Protection (LTOP) System, provides the maximum allowable actuation logic setpoints for the power operated relief valves (PORVs) during cooldown, shutdown, and heatup to keep from violating the pressure and temperature limits.

LTOP instrumentation is addressed in TS 3.4.12.

The RCS Leakage Detection Instrumentation provides the means for detecting RCS leakage.

An early indication or warning signal is necessary to permit proper evaluation of all unidentified leakage. The RCS Leakage Detection Instrumentation is addressed in TS 3.4.15, RCS Leakage Detection Instrumentation.

The RTS, ESFAS, PAM, RSS, DNB Limits, LTOP, and RCS Leakage Detection Instrumentation transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection will be provided in AMS report CAT2501R, "OLM Amenable Transmitters Report for Catawba Units 1 and 2.

Switching from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies will not create any physical changes to the plant. The changes will not

Enclosure to RA-24-0273 Evaluation of Proposed Change E-5 impact how the plant operates. Duke Energy will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.

2.2.3 McGuire Nuclear Station Units 1 and 2 The transmitters to be included in the Online Monitoring Program provide input to the RTS and ESFAS and are used for PAM, the RSS, RCS Pressure, Temperature, and Flow DNB Limits, LTOP, and RCS Leakage Detection Instrumentation.

The RTS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and RCS pressure boundary during anticipated operational occurrences and to assist the Engineered Safety Features Systems in mitigating accidents. The RTS and related instrumentation are identified in TS Table 3.3.1-1, Reactor Trip System Instrumentation.

The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the RCS pressure boundary, and to mitigate accidents. The ESFAS-related instrumentation is identified in TS Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation.

The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents. The PAM instrumentation is identified in TS Table 3.3.3-1, Post Accident Monitoring Instrumentation.

The RSS provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. The RSS instrumentation is identified in TS Table 3.3.4-1, Remote Shutdown System Instrumentation and Controls.

The DNB limits address requirements for maintaining RCS pressure, temperature, and flow rate within limits assumed in the safety analyses. The safety analyses of normal operating conditions and anticipated operational occurrences assume initial conditions within the normal steady state envelope. The limits placed on RCS pressure, temperature, and flow rate ensure that the minimum DNB ratio will be met for each of the transients analyzed.

The RCS pressure limit is consistent with operation within the nominal operational envelope.

Pressurizer pressure indications are averaged to produce a value for comparison to the limit. A lower pressure will cause the reactor core to approach DNB limits. Flow rate indications are averaged within a loop and then summed among the four loops to come up with a value for comparison to the limit. A lower RCS flow will cause the core to approach DNB limits.

The LTOP System controls RCS pressure at low temperatures, so the integrity of the reactor coolant pressure boundary is not compromised by violating the pressure and temperature limits.

TS 3.4.12, Low Temperature Overpressure Protection (LTOP) System, provides the maximum allowable actuation logic setpoints for the PORVs during cooldown, shutdown, and heatup to keep from violating the pressure and temperature limits. The LTOP instrumentation is addressed in TS 3.4.12.

The RCS Leakage Detection Instrumentation provides the means for detecting RCS leakage.

An early indication or warning signal is necessary to permit proper evaluation of all unidentified

Enclosure to RA-24-0273 Evaluation of Proposed Change E-6 leakage. The RCS Leakage Detection Instrumentation is addressed in TS 3.4.15, RCS Leakage Detection Instrumentation.

The RTS, ESFAS, PAM, RSS, DNB Limits, LTOP, and RCS Leakage Detection Instrumentation transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection will be provided in AMS report MCG2405R0, "OLM Amenable Transmitters Report for McGuire Units 1 and 2.

Switching from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies will not create any physical changes to the plant. The changes will not impact how the plant operates. Duke Energy will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.

2.2.4 H.B. Robinson Steam Electric Plant Unit No. 2 The transmitters to be included in the Online Monitoring Program provide input to the RPS, ESFAS, and Auxiliary Feedwater (AFW) System and are used for PAM, RSS, LTOP, and RCS Leakage Detection Instrumentation.

The RPS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and RCS pressure boundary during anticipated operational occurrences and to assist the Engineered Safety Features Systems in mitigating accidents. The RPS and related instrumentation are identified in TS Table 3.3.1-1, Reactor Protection System Instrumentation.

The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the Reactor Coolant System (RCS) pressure boundary, and to mitigate accidents. The ESFAS-related instrumentation is identified in TS Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation.

The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents. The PAM instrumentation is identified in TS Table 3.3.3-1, Post Accident Monitoring Instrumentation.

The RSS provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. The RSS instrumentation is addressed in TS 3.3.4, Remote Shutdown System, and described in Updated Final Safety Analysis Report (UFSAR) Section 7.4, Systems Required for Safe Shutdown.

The AFW System automatically supplies feedwater to the steam generators to remove decay heat from the RCS upon loss of normal feedwater supply. Initiation of an automatic actuation signal to the turbine-driven AFW pump causes the turbine steam supply valves and the pump feedwater discharge isolation valves to open. An automatic actuation signal to the motor-driven AFW pumps cause the pumps to become energized and accelerate up to speed, and the feedwater discharge isolation valves to open. The AFW System instrumentation is addressed in TS 3.3.8, Auxiliary Feedwater (AFW) System Instrumentation.

The LTOP System controls RCS pressure at low temperatures, so the integrity of the reactor coolant pressure boundary is not compromised by violating the pressure and temperature limits.

Enclosure to RA-24-0273 Evaluation of Proposed Change E-7 The LTOP instrumentation is addressed in TS 3.4.12, Low Temperature Overpressure Protection (LTOP) System.

The RCS Leakage Detection Instrumentation provides the means for detecting RCS leakage.

An early indication or warning signal is necessary to permit proper evaluation of all unidentified leakage. The containment sump used to collect unidentified leakage is instrumented to detect increases above the normal flow rates. The fan cooler condensate measuring system monitors are instrumented to alarm for increases above the normal flow rates. The RCS Leakage Detection Instrumentation is addressed in TS 3.4.15, RCS Leakage Detection Instrumentation.

The RPS, ESFAS, PAM, RSS, AFW, LTOP, and RCS Leakage Detection Instrumentation transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection will be provided in AMS report HBR2501R0, "OLM Amenable Transmitters Report for H.B. Robinson Unit 2.

Switching from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies will not create any physical changes to the plant. The changes will not impact how the plant operates. Duke Energy will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.

2.3 Reason for the Proposed Change Duke Energy is proposing to use the NRC-approved OLM methodology described in AMS-TR-0720R2-A. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly. The OLM methodology encompasses environmental and process conditions in the assessment of transmitter calibration.

The use of condition-based monitoring for transmitter calibration provides additional safety benefits, as described in AMS-TR-0720R2-A. The use of OLM will result in elimination of unnecessary transmitter calibration and associated opportunities for human errors. Elimination of unnecessary calibrations will also reduce calibration-induced damage to transmitters and other plant equipment. The use of OLM provides for timely detection of out-of-calibration transmitters. It eliminates occupational exposure and human error opportunities related to calibration activities that were unnecessary. Experience has shown that human errors during calibration of transmitters that did not require recalibration have resulted in additional repairs to correct the mistakes.

2.4 Description of the Proposed Change The proposed TS changes are an adaptation from the illustrative changes presented in AMS-TR-0720R2-A that simplify the required plant-specific changes. The proposed Definition changes eliminates the need to modify the Channel Calibration and Response Time Surveillance Requirements. The proposed Online Monitoring Program description is reorganized to better align with the OLM implementation activities.

2.4.1 Brunswick Steam Electric Plant Units 1 and 2 Duke Energy proposes to change the definition of CHANNEL CALIBRATION in BSEP TS 1.1 Definitions.

Current definition of 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

Enclosure to RA-24-0273 Evaluation of Proposed Change E-8 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. 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 so that the entire channel is calibrated.

Proposed definition of 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 (excluding transmitters in the Online Monitoring Program),

alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST.

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 so that the entire channel is calibrated.

Duke Energy proposes adding a new TS 5.5.16, Online Monitoring Program for BSEP, as shown below.

5.5.16 Online Monitoring Program This program provides controls to determine the need for calibration for 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 shall 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. The Online Monitoring Program shall contain a list of transmitters included in the program, determined in accordance with AMS-TR-0720R2-A.

b. Online monitoring evaluation of transmitters in the program shall include the following:

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

c. Performance of calibration checks during the next refueling outage of any transmitters identified as requiring a calibration check or that were not evaluated in accordance with Paragraph b.

Enclosure to RA-24-0273 Evaluation of Proposed Change E-9

d. Performance of calibration checks at the backstop interval determined in accordance with AMS-TR-0720R2-A.

e. Appropriate actions in the event calibration checks are not performed as specified by the program.

2.4.2 Catawba Nuclear Station Units 1 and 2 Duke Energy proposes to change the definition of CHANNEL CALIBRATION in CNS TS 1.1 Definitions.

Current definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions. 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. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated.

Proposed definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions (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. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated.

Duke Energy proposes adding a new TS 5.5.18, Online Monitoring Program for CNS, as shown below.

5.5.18 Online Monitoring Program This program provides controls to determine the need for calibration for 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 shall 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:

Enclosure to RA-24-0273 Evaluation of Proposed Change E-10

a. The Online Monitoring Program shall contain a list of transmitters included in the program, determined in accordance with AMS-TR-0720R2-A.

b. Online monitoring evaluation of transmitters in the program shall include the following:

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

c. Performance of calibration checks during the next refueling outage of any transmitters identified as requiring a calibration check or that were not evaluated in accordance with Paragraph b.

d. Performance of calibration checks at the backstop interval determined in accordance with AMS-TR-0720R2-A.

e. Appropriate actions in the event calibration checks are not performed as specified by the program.

2.4.3 McGuire Nuclear Station Units 1 and 2 Duke Energy proposes to change the definition of CHANNEL CALIBRATION in MNS TS 1.1 Definitions.

Current definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions. 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. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated.

Proposed definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions (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. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross

Enclosure to RA-24-0273 Evaluation of Proposed Change E-11 calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated.

Duke Energy proposes adding a new TS 5.5.19, Online Monitoring Program for MNS, as shown below.

5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration for 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 shall 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. The Online Monitoring Program shall contain a list of transmitters included in the program, determined in accordance with AMS-TR-0720R2-A.

b. Online monitoring evaluation of transmitters in the program shall include the following:

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

c. Performance of calibration checks during the next refueling outage of any transmitters identified as requiring a calibration check or that were not evaluated in accordance with Paragraph b.

d. Performance of calibration checks at the backstop interval determined in accordance with AMS-TR-0720R2-A.

e. Appropriate actions in the event calibration checks are not performed as specified by the program.

2.4.4 H.B. Robinson Steam Electric Plant Unit No. 2 Duke Energy proposes to change the definition of CHANNEL CALIBRATION in HBRSEP TS 1.1 Definitions.

Current definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions. Calibration of instrument channels with resistance

Enclosure to RA-24-0273 Evaluation of Proposed Change E-12 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. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated.

Proposed definition of CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions (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. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated.

Duke Energy proposes adding a new TS 5.5.19, Online Monitoring Program for HBRSEP, as shown below.

5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration for 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 shall 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. The Online Monitoring Program shall contain a list of transmitters included in the program, determined in accordance with AMS-TR-0720R2-A.

b. Online monitoring evaluation of transmitters in the program shall include the following:

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

Enclosure to RA-24-0273 Evaluation of Proposed Change E-13

c. Performance of calibration checks during the next refueling outage of any transmitters identified as requiring a calibration check or that were not evaluated in accordance with Paragraph b.

d. Performance of calibration checks at the backstop interval determined in accordance with AMS-TR-0720R2-A.

e. Appropriate actions in the event calibration checks are not performed as specified by the program.

3 TECHNICAL EVALUATION 3.1 OLM Implementation Process Development This section describes the steps that were performed to implement the OLM program for BSEP, CNS, MNS, and HBRSEP by following the steps identified in AMS-TR-0720R2-A Section 11.1.1. This work will be documented in the AMS reports on OLM Amenable Transmitters and OLM Analysis Methods and Limits.

The AMS reports on OLM Amenable Transmitters will address steps 1-6 from AMS-TR-0720R2-A Section 11.1.1. These steps were designed to arrive at a list of transmitters that can be included in an OLM program and determine how to obtain OLM data. The BSEP, CNS, MNS, and HBRSEP transmitters to be included in the OLM program and the bases for their selection will be provided in the AMS reports on OLM Amenable Transmitters.

3.1.1 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.

3.1.2 List Transmitters in Each Redundant Group This step establishes how to group the transmitters and evaluates the redundancy of each group.

3.1.3 Determine if OLM Data Covers Applicable Setpoints This step evaluates the OLM data for each group to determine if it covers applicable setpoints.

Additional details are described in AMS-TR-0720R2-A Chapter 14.

3.1.4 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.

3.1.5 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.

3.1.6 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

Enclosure to RA-24-0273 Evaluation of Proposed Change E-14 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.

AMS reports on OLM Analysis Methods and Limits will address steps 7-8 from AMS-TR-0720R2-A Section 11.1.1 These steps address the calculation of the OLM limits and establish the methods of OLM data analysis.

3.1.7 Identify Data Analysis Methods OLM implementations must employ both simple averaging and parity space methods for data analysis as described in AMS-TR-0720R2-A Chapter 6.

3.1.8 Establish OLM Limits OLM limits must be established as described in AMS-TR-0720R2-A Chapter 7 for each group of redundant transmitters. Calculation of OLM limits must be based on combining uncertainties of components of each instrument channel from the transmitter in the field to the OLM data storage.

The AMS report on OLM Analysis Methods and Limits will provide the OLM Limit calculations for the transmitters that are amenable to OLM at BSEP, CNS, MNS, and HBRSEP.

3.2 OLM Program Implementation This section summarizes the steps that must be followed to implement the OLM Program for transmitter drift monitoring at BSEP, CNS, MNS, and HBRSEP in accordance with AMS-TR-0720R2-A. The steps described in this section are repeated at each operating cycle at BSEP, CNS, MNS, and HBRSEP to identify the transmitters that should be scheduled for a calibration check using data from periods of startup, normal operation, and shutdown. Additional details regarding the OLM Program implementation discussed in this section will be provided in the AMS reports on OLM Drift Monitoring Program.

AMS-TR-0720R2-A Section 11.1.2 identifies eleven steps that must be followed each operating cycle to identify the transmitters that should be scheduled for a calibration check at the ensuing outage. Table 1 provides a mapping between AMS-TR-0720R2-A Section 11.1.2 and the LAR section where the item is addressed. Implementation of these steps is performed using the AMS Bridge and the AMS Calibration Reduction System (CRS) software programs that were developed by AMS under their 10 CFR Part 50 Appendix B software Quality Assurance (QA) program.

Table 1: Mapping to AMS-TR-0720R2-A Section 11.1.2 Item Step Step Number in Section 11.1.2 of AMS-TR-0720R2-A LAR Section 1

Retrieve OLM Data 9

3.2.1 2

Perform Data Qualification 10 3.2.2 3

Select Appropriate Region of Any Transient Data 11 3.2.3 4

Perform Data Analysis 12 3.2.4

Enclosure to RA-24-0273 Evaluation of Proposed Change E-15 Item Step Step Number in Section 11.1.2 of AMS-TR-0720R2-A LAR Section 5

Plot the Average Deviation for Each Transmitter 13 3.2.5 6

Produce a Table for Each Group That Combines All Results 14 3.2.6 7

Determine OLM Results for Each Transmitter 15 3.2.7 8

Address Uncertainties in the Unexercised Portion of Transmitter Range 16 3.2.8 9

Select Transmitters to Be Checked for Calibration as a Backstop 17 3.2.9 10 Perform Dynamic Failure Mode Assessment 18 3.2.10 11 Produce a Report of Transmitters Scheduled for Calibration Check 19 3.2.11 3.2.1 Retrieve OLM Data The first step in performing transmitter drift monitoring is to retrieve the OLM data. OLM data must be retrieved during periods of startup, normal operation, and shutdown. The method of data acquisition, data collection duration, sampling rate, and list of sensors whose data will be retrieved have been established as described in Section 3.1 of this document. The OLM data for BSEP, CNS, MNS, and HBRSEP will be retrieved using the AMS Bridge software which will retrieve data from the plant data historian and produce binary data files that are compatible with the AMS Calibration Reduction System (CRS) software or as text files from the data historian or other data sources at each plant site, as applicable. AMS procedure OLM2201, Procedure for Online Monitoring Data Retrieval, has been developed for performing the data retrieval using the AMS Bridge software (Reference 15).

3.2.2 Perform Data Qualification OLM data retrieved from plant historians sometimes contains anomalies such as spikes, missing data, stuck data, and saturated data. The portion of data containing these anomalies should be excluded, filtered, and/or cleaned prior to analysis. The AMS CRS software provides functionality for these tasks and will be used to perform data qualification. AMS procedure OLM2202, Procedure for Performing Online Monitoring Data Qualification and Analysis, has been developed for performing data qualification and analysis using the AMS CRS software (Reference 16).

3.2.3 Select Appropriate Region of Any Transient Data The AMS CRS software provides means to select the regions of transient data as described in Step 11 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform these selections.

This activity is part of OLM data analysis and is addressed in the data qualification and analysis procedure.

3.2.4 Perform Data Analysis Several tasks that must be performed in OLM data analysis for startup, normal operation, and shutdown data include:

1. Calculate the process estimate,

Enclosure to RA-24-0273 Evaluation of Proposed Change E-16

2. Calculate the deviation of each transmitter from the process estimate and plot the

outcome,

3. Partition the deviation data into region(s) by percent of span,

4. Calculate and plot the average deviation for each region versus percent of span,

5. Select appropriate process estimation techniques, filtering parameters, and remove any

outliers,

6. Determine if average deviations exceed OLM limits for any region, and

7. Review, document, and store the details and results of analysis.

The AMS CRS software provides functionality for performing these tasks and will be used to perform OLM data analysis. Detailed steps for performing OLM data analysis are provided in the data qualification and analysis procedure.

3.2.5 Plot the Average Deviation for Each Transmitter The AMS CRS software provides functionality for plotting the average deviation for each transmitter as described in Step 13 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.6 Produce a Table for Each Group That Combines All Results The AMS CRS software provides functionality for producing a table for each group of redundant transmitters that combines all results as described in Step 13 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.7 Determine OLM Results for Each Transmitter OLM results must be produced by the OLM analyst upon completion of data analysis for a complete operating cycle. The AMS CRS software provides functionality for producing these results as described in Step 15 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.8 Address Uncertainties in the Unexercised Portion of Transmitter Range The AMS CRS software provides functionality for addressing uncertainties in the unexercised portion of the transmitter range as described in Step 13 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.9 Select Transmitters to Be Checked for Calibration as a Backstop The AMS procedure OLM2202 is also used for maintaining the backstops for OLM. It provides detailed steps for selecting transmitters to be checked for calibration as a backstop as described in Step 17 of Section 11.1.2 of AMS-TR-0720R2-A.

3.2.10 Perform Dynamic Failure Mode Assessment As described in Step 18 of Section 11.1.2 of AMS-TR-0720R2-A, dynamic failure mode assessment must be performed using the noise analysis technique to cover dynamic failures that are not detectable by the OLM process for transmitter drift monitoring. Details on how this will be addressed for BSEP, CNS, MNS, and HBRSEP are described in LAR Section 3.3.

Enclosure to RA-24-0273 Evaluation of Proposed Change E-17 3.2.11 Produce a Report of Transmitters Scheduled for Calibration Check The results of OLM analysis must be compiled in a report and independently reviewed. The transmitters that have been flagged must be scheduled for a calibration check at the next opportunity. The AMS CRS software provides functionality for producing this report and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.3 OLM Noise Analysis Implementation Duke Energy has previously extended or eliminated transmitter response time testing requirements with NRC approval based, in part, on the performance of manual calibrations.

Manual calibrations will not be performed except on transmitters that are flagged by OLM. The noise analysis methodology is provided to assess the dynamic failure modes of transmitters that are not covered by the OLM transmitter drift monitoring technique.

This section summarizes the steps that must be followed to implement the noise analysis technique for transmitter dynamic failure mode assessment at BSEP, CNS, MNS, and HBRSEP in accordance with AMS-TR-0720R2-A. Additional details regarding the implementation of the noise analysis technique discussed in this section will be provided in the AMS reports on Noise Analysis Program.

As described in Section 11.3.3 of AMS-TR-0720R2-A, six steps must be followed to assess dynamic failure modes of pressure transmitters. Table 2 provides a mapping of the six steps in Section 11.3.3 of AMS-TR-0720R2-A and the section where they are addressed in this document. Implementation of these steps is performed using qualified noise data acquisition equipment and software programs that were developed by AMS under their 10 CFR Part 50 Appendix B software Quality Assurance (QA) program.

For BSEP, CNS, MNS, and HBRSEP, the transmitters with response time requirements will be identified in AMS reports on OLM Amenable Transmitters.

Table 2: Mapping to AMS-TR-0720R2-A Section 11.3.3 Item Step Step Number in Section 11.3.3 of AMS-TR-0720R2-A LAR Section 1

Select Qualified Noise Data Acquisition Equipment 1

3.3.1 2

Connect Noise Data Acquisition Equipment to Plant Signals 2

3.3.2 3

Collect and Store Data for Subsequent Analysis 3

3.3.3 4

Screen Data for Artifacts and Anomalies 4

3.3.4 5

Perform Data Analysis 5

3.3.5 6

Review and Document Results 6

3.3.6

Enclosure to RA-24-0273 Evaluation of Proposed Change E-18 3.3.1 Select Qualified Noise Data Acquisition Equipment The first step in performing noise analysis is to select qualified noise data acquisition equipment. This equipment must have a valid calibration traceable to the National Institute of Standards and Technology and meet a set of performance criteria detailed Step 1 of Section 11.3.3 of AMS-TR-0720R2-A. The equipment used to acquire data at BSEP, CNS, MNS, and HBRSEP will be the AMS OLM data acquisition system which is comprised of hardware and software that has been developed and tested using AMS 10 CFR Part 50 Appendix B hardware and software QA program.

3.3.2 Connect Noise Data Acquisition Equipment to Plant Signals AMS Procedure NPS1501, Procedure for Noise Data Collection from Plant Sensors, (Reference 21) is used for the connection of the noise data acquisition equipment for performing noise analysis testing. This procedure identifies the locations for connection to process signals as well as the qualified personnel who may connect the data acquisition system at these locations. The noise data acquisition system should be connected to as many transmitters as allowed by the number of data acquisition channels and the plant procedures. Multiple transmitters (e.g., up to 32) can be tested simultaneously to reduce the test time. Each data acquisition channel must be connected to the transmitter current loop as shown in Section 11.3.3 of AMS-TR-0720R2-A.

3.3.3 Collect and Store Data for Subsequent Analysis The noise data should be collected during normal plant operation at full temperature, pressure, and flow and analyzed in real time or stored to be analyzed later. However, noise data taken at other conditions is acceptable as long as there is enough process fluctuation with sufficient amplitude and frequency content to drive the transmitters to reveal their dynamic characteristics.

Noise data collection will be performed using AMS OLM Data Acquisition software which has been developed and tested using AMS software verification and validation program which conforms to 10 CFR Part 50 Appendix B. The use of this software for noise data acquisition is addressed in the AMS procedure for performing noise analysis testing (Reference 21).

3.3.4 Screen Data for Artifacts and Anomalies Noise data may contain anomalies that must be excluded, filtered, and/or cleaned prior to data analysis. AMS Procedure NAR2201, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis, is used for performing noise analysis data analysis (Reference 22) and will be performed using AMS noise analysis software.

3.3.5 Perform Data Analysis Noise data analysis will be performed as described in Section 11.3.3 Step 5 in AMS-TR-0720R2-A using AMS noise analysis software. General data analysis steps for the analyst as well as detailed steps for performing noise data analysis are also provided in the AMS procedure for performing noise analysis data analysis (Reference 22).

3.3.6 Review and Document Results Results of noise data analysis will be reviewed and approved by qualified personnel and documented in a report. This process is detailed in the AMS procedure for performing noise analysis data analysis (Reference 22).

3.4 Application-Specific Action Items from AMS OLM TR The NRC approval of the AMS OLM TR required implementation of the ASAIs in Section 4.0 of its safety evaluation. Five ASAIs were identified, and each is addressed below.

Enclosure to RA-24-0273 Evaluation of Proposed Change E-19 ASAI 1 - Evaluation and Proposed Mark-up of Existing Plant Technical Specifications When preparing a license amendment request to adopt OLM methods for establishing calibration frequency, licensees should consider markups that provide clear requirements for accomplishing plant operations, engineering data analysis, and instrument channel maintenance. Such TS changes would need to include appropriate markups of the TS tables describing limiting conditions for operation and surveillance requirements, the technical basis for the changes, and the administrative programs section.

Response to ASAI 1: The proposed changes to the BSEP, CNS, MNS, and HBRSEP Technical Specifications are identified in Section 2.4 and shown in Attachments 1, 3, 5, 7, and

9. The proposed changes modify applicable Definitions and add a new program for OLM in the Administrative Controls. No changes to the Technical Specification tables describing Limiting Conditions for Operation or Surveillance Requirements were necessary.

ASAI 2 - Identification of Calibration Error Source When determining whether an instrument can be included in the plant OLM program, the licensee shall evaluate calibration error source in order to account for the uncertainty due to multiple instruments used to support the transfer of transmitter signal data to the data collection system. Calibration errors identified through OLM should be attributed to the transmitter until testing can be performed on other support devices to correctly determine the source of calibration error and reallocate errors to these other loop components.

Response to ASAI 2: Calibration error is evaluated as part of the calculation of OLM limits as described in Section 3.1.8. The calculation of OLM limits is based on combining uncertainties of components of each instrument channel from the transmitter in the field to the OLM data storage. The OLM data assessment methods described in Section 3.2.7 include guidance to consider calibration errors identified through OLM as coming from the transmitter until testing can be performed on other support devices to correctly determine the source of calibration error and reallocate errors to these other loop components.

ASAI 3 - Response Time Test Elimination Basis If the plant has eliminated requirements for performing periodic RT [response time] testing of transmitters to be included in the OLM program, then the licensee shall perform an assessment of the basis for RT test elimination to determine if this basis will remain valid upon implementation of the OLM program and to determine if the RT test elimination will need to be changed to credit the OLM program rather than the periodic calibration test program.

Response to ASAI 3: BSEP, CNS and MNS previously eliminated requirements for performing periodic response time testing based on the periodic calibration of transmitters that are proposed to be included in the OLM Program. BSEP, CNS and MNS propose to change the basis for response time test elimination to the methodology described in Section 3.3, which is based on the noise analysis methodology described in Section 11.3 of the AMS OLM TR. The HBRSEP TS does not contain response time surveillance requirements.

ASAI 4 - Use of Calibration Surveillance Interval Backstop In its application for a license or license amendment to incorporate OLM methods for establishing calibration surveillance intervals, applicants or licensees should describe how they intend to apply backstop intervals as a means for mitigating

Enclosure to RA-24-0273 Evaluation of Proposed Change E-20 the potential that a process group could be experiencing undetected common mode drift characteristics.

Response to ASAI 4: The Duke Energy OLM programs for BSEP, CNS, MNS, and HBRSEP adopt the calibration surveillance interval backstop methods described in Section 3.2.9, which are based on the backstop methodology described in Section 13 of the AMS OLM TR.

The use of AMS-TR-0720R2-A to switch from time-based calibration frequency of pressure, level, and flow transmitters to a condition-based calibration frequency based on OLM results will be added to the appropriate parts of BSEP, CNS, MNS, and HBRSEP UFSAR Chapter 7, including a list of transmitters included in the OLM Program. The appropriate parts of UFSAR Chapter 7 will also be updated to describe the use of OLM to assess dynamic failure modes of pressure-type sensing systems using the noise analysis technique to support the continued elimination of transmitter response time testing.

ASAI 5 - Use of Criteria other than in AMS OLM TR for Establishing Transmitter Drift Flagging Limit In its application for a license or license amendment to incorporate OLM methods for establishing calibration surveillance intervals, applicants or licensees should describe whether they intend to adopt the criteria within the AMS OLM TR for flagging transmitter drift or whether they plan to use a different methodology for determining this limit.

Response to ASAI 5: The Duke Energy OLM programs for BSEP, CNS, MNS, and HBRSEP adopt the two averaging techniques (i.e., simple average and parity space) described in Section 6 of the AMS OLM TR for flagging transmitter drift.

4 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 Technical Specifications. Part (3) of this regulation sets the governing requirements for the inclusion of Surveillance Requirements in the Technical Specifications included in the Operating License for a commercial nuclear power plant.

(3) Surveillance requirements. 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.

Duke Energy proposes to use the AMS OLM methodology for BSEP, CNS, MNS, and HBRSEP as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies based on OLM results.

10 CFR Part 50 Appendix A. General Design Criterion 21, Protection System Reliability and Testability, requires, in part, that plant protection systems be designed to permit periodic testing during reactor operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.

Criterion 21, Protection System Reliability and Testability. The protection system shall be designed for high functional reliability and in-service testability commensurate with the safety functions to be performed. Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required

Enclosure to RA-24-0273 Evaluation of Proposed Change E-21 minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated. The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.

General Design Criterion 21 is applicable to BSEP, CNS and MNS but its equivalent for HBRSEP is General Design Criterion 19 due to the vintage of the plant.

Duke Energy proposes to use the AMS OLM methodology for BSEP, CNS, MNS, and HBRSEP as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies based on OLM results. The OLM methodology is also proposed to be used to assess dynamic failure modes of pressure sensing systems.

Regulatory Guide 1.118, Revision 3. Regulatory Guide 1.118, Revision 3, Periodic Testing of Electric Power and Protection Systems, endorses with qualification the IEEE Standard 338-1987, IEEE Standard Criteria for the Periodic Surveillance Testing of Nuclear Power Generating Station Safety Systems. Regulatory Guide 1.118, is applicable to CNS and MNS but BSEP and HBRSEP did not adopt due to the vintage of the plant.

Duke Energy proposes to use the AMS OLM methodology as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies based on OLM results.

IEEE Standard 338-1977. This standard contains the following requirements related to calibration:

6.3.3 Channel Calibration Verification Tests. A channel calibration verification test should prove that with a known precise input, the channel gives the required output, analog, or bistable. Additionally, in analog channels, linearity and hysteresis may be checked. If the required output is achieved, the test is acceptable. If the required output is not achieved (for example, the bistable trip did not occur at the required set point or the analog output was out of tolerance) or saturation or foldover is observed and adjustment or alignment of gain, bias, trip set, etc., is required, the test is unacceptable. Adjustment or alignment procedures are maintenance activities and are outside the scope of this standard. Test results, however, shall be recorded in accordance with ANSI/ANS 3.2-1982, or the equivalent. Following maintenance or other appropriate disposition of the unacceptable results, a successful rerun of the channel calibration verification test shall be performed.

6.5.2 Changes to Test Interval. The effect of testing intervals on performance of equipment shall be reevaluated periodically to determine if the interval used is an effective factor in maintaining equipment in an operational status. The following shall be considered:

History of equipment performance, particularly experienced failure rates and potential significant increases in failure rates.

Corrective action associated with failures.

Performance of equipment in similar plants or environment, or both.

Plant design changes associated with equipment.

Detection of significant changes of failure rates.

Enclosure to RA-24-0273 Evaluation of Proposed Change E-22 Test intervals may be changed to agree with plant operational modes provided it can be shown that such changes do not adversely affect desired performance of the equipment being tested. Tests need not be performed on systems or equipment when they are not required to be operable or are tripped. If tests are not conducted on such systems, they shall be performed prior to returning the system to operation.

Duke Energy proposes to use the AMS OLM methodology for BSEP, CNS, MNS, and HBRSEP as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies based on OLM results for a given transmitter.

IEEE Standard 338-2012. This standard contains the following requirements related to calibration:

5.3.3.2 On-line monitoring. On-line monitoring (OLM) techniques enable the determination of portions of an instrument channels status during plant operation. This methodology is an acceptable input for establishing calibration frequency of those monitored portions of instrument channels without adversely affecting reliability.

Continuous monitoring shall be employed, e.g., through the plant computer.

Periodic manual testing is either a maintenance or surveillance task and is not on-line monitoring.

On-line monitoring shall ensure that setpoint calculation assumptions and the safety analysis assumptions remain valid.

Duke Energy proposes to use the AMS OLM methodology for BSEP, CNS, MNS, and HBRSEP as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies based on OLM results for a given transmitter.

4.2 Precedent The Duke Energy license amendment request is based on the NRC-approved Analysis and Measurement Services Corporation Topical Report AMS-TR-0720R2, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (References 1 and 2). Three precedents were identified: 1) NRC approved license amendment request submitted by Southern Nuclear Operating Company for Vogtle Electric Generating Plant Units 1 and 2 to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2 (References 23 and 24); 2) NRC approved license amendment request submitted by Southern Nuclear Operating Company for Farley Nuclear Plant, Units 1 and 2, and Edwin I.

Hatch Nuclear Plant, Units 1 and 2, to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2 (References 25 and 26); 3) NRC approved license amendment request submitted by Pacific Gas and Electric Company for Diablo Canyon Power Plant to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2 (References 27 and 28).

It is noted that the TS Markup for the addition of the Online Monitoring Program for each site (TS 5.5.XX) has wording that differs from the submittals noted in the above precedence discussion. The program description, in general, has been revised to provide additional clarification related to the components of and the tasks performed by the program, along with two additional adjustments.

Enclosure to RA-24-0273 Evaluation of Proposed Change E-23 The first change is a requirement for the OLM Program to contain a list of transmitters included in the program so that Operators and other stakeholders are able to identify OLM-scope components as needed.

Secondly, the reference to Surveillance Requirement (SR) 3.0.3 has been revised to note that the OLM Program shall provide appropriate actions in the event calibration checks were not performed as specified by the program. This change ensures clarity considering that OLM transmitter calibration checks are not Surveillance Requirements and do not have a specified Frequency. If a calibration check is determined to not have been performed as specified by the program, the condition will be entered into the Corrective Action Program and evaluated for operability, and actions will be taken to correct the condition on a schedule commensurate with the safety significance.

Also, BSEP, CNS, and MNS Response Time TS definitions are unmodified as the TS already allow the use of the design sensor (BSEP) and allocated (CNS, MNS) response times in response time testing. For BSEP, this allowance is included in Notes of the associated SRs, whereas for CNS and MNS, the Response Time definition allows the use of NRC approved methods for Response Time verification. Similarly, the associated TS Bases for Response Time SRs are revised only to note the role of noise analysis in design sensor and allocated response times within OLM.

4.3 No Significant Hazards Consideration Determination Analysis Duke Energy Carolinas, LLC and Duke Energy Progress, LLC, (collectively referenced as Duke Energy) has evaluated the proposed changes to the BSEP, CNS, MNS, and HBRSEP Technical Specifications (TS) using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

The proposed changes revise the following TSs:

BSEP TS 1.1 definition for CHANNEL CALIBRATION CNS TS 1.1 definition for CHANNEL CALIBRATION MNS TS 1.1 definition for CHANNEL CALIBRATION HBRSEP TS 1.1 definition for CHANNEL CALIBRATION The proposed changes add new Online Monitoring Program TSs, as shown below:

BSEP TS 5.5.16 Online Monitoring Program CNS TS 5.5.18 Online Monitoring Program MNS TS 5.5.19 Online Monitoring Program HBRSEP TS 5.5.19 Online Monitoring Program Duke Energy proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies based on OLM results. Switching from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies will not create any physical changes to the plant. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly.

As required by 10 CFR 50.91(a), the Duke Energy analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

Enclosure to RA-24-0273 Evaluation of Proposed Change E-24 The proposed change uses online monitoring methodology as the technical basis to switch from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies based on OLM results. Switching from time-based surveillance frequencies for channel calibrations to condition-based calibration frequencies will not create any physical changes to the plant. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly.

The proposed change does not adversely affect accident initiators or precursors, and does not alter the design assumptions, conditions, or configuration of the plant or the way the plant is operated or maintained.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

Existing calibration methods will be used when the need for transmitter calibration is determined. The change does not alter assumptions made in the safety analysis but ensures that the transmitters operate as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

The change does not alter assumptions made in the safety analysis but ensures that the transmitters operate as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.

5 Environmental Consideration The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore,

Enclosure to RA-24-0273 Evaluation of Proposed Change E-25 pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the proposed change. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the issuance of the amendment.

6 References (AMS plant-specific reports are proprietary, currently under development, and will be made available for Audit)

1. Analysis and Measurement Services Corporation letter to NRC dated August 20, 2021, 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), (ADAMS Accession No. ML21235A493)

2. NRC Form 896, AMS Topical Report -A Verification, dated September 22, 2021 (ADAMS Accession No. ML21237A490)

3. AMS Report BRU2501R0, OLM Amenable Transmitters Report for Brunswick Units 1 and 2

4. AMS Report CAT2501R0, "OLM Amenable Transmitters Report for Catawba Units 1 and 2

5. AMS Report MCG2405R0, "OLM Amenable Transmitters Report for McGuire Units 1 and 2

6. AMS Report HBR2501R0, "OLM Amenable Transmitters Report for H.B. Robinson Unit 2

7. AMS Report BRU2502R0, OLM Analysis Methods and Limits Report for Brunswick Units 1 and 2

8. AMS Report CAT2502R0, OLM Analysis Methods and Limits Report for Catawba Units 1 and 2

9. AMS Report MCG2406R0, OLM Analysis Methods and Limits Report for McGuire Units 1 and 2

10. AMS Report HBR2504R0, OLM Analysis Methods and Limits Report for H.B. Robinson Unit 2

11. AMS Report BRU2503R0, OLM Drift Monitoring Program Report for Brunswick Units 1 and 2

12. AMS Report CAT2503R0, OLM Drift Monitoring Program Report for Catawba Units 1 and 2

13. AMS Report MCG2407R0, OLM Drift Monitoring Program Report for McGuire Units 1 and 2

14. AMS Report HBR2503R0, OLM Drift Monitoring Program Report for H.B. Robinson Unit 2

15. AMS Procedure OLM2201, Procedure for Online Monitoring Data Retrieval, December 2022

Enclosure to RA-24-0273 Evaluation of Proposed Change E-26

16. AMS Procedure OLM2202, Procedure for Performing Online Monitoring Data Qualification and Analysis, August 2024

17. AMS Report BRU2504R0, OLM Noise Analysis Program Report for Brunswick Units 1 and 2

18. AMS Report CAT2504R0, OLM Noise Analysis Program Report for Catawba Units 1 and 2

19. AMS Report MCG2408R0, OLM Noise Analysis Program Report for McGuire Units 1 and 2

20. AMS Report HBR2504R0, OLM Noise Analysis Program Report for H.B. Robinson Unit 2

21. AMS Procedure NPS1501, Procedure for Noise Data Collection from Plant Sensors, March 2015

22. AMS Procedure NAR2201, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis, August 2024

23. Southern Nuclear Operating Company letter NL-22-0764 to NRC dated December 21, 2022, License Amendment Request to Revise Technical Specification 1.1 and Add 5.5.23 to Use Online Monitoring Methodology, (ADAMS Accession No. ML22355A588)

24. NRC letter to Southern Nuclear Operating Company dated June 15, 2023, Vogtle Electric Generating Plant, Units 1 And 2 - Issuance of Amendments Regarding Revision to Technical Specifications to Use Online Monitoring Methodology, (ADAMS Accession No. ML23115A149)

25. Southern Nuclear Operating Company letter NL-24-0064 to NRC dated May 3, 2024, Farley Nuclear Plant - Units 1&2 and Hatch Nuclear Plant - Units 1&2 License Amendment Request to Revise Technical Specification 1.1 and Add Online Monitoring Program to Technical Specification 5.5, (ADAMS Accession No. ML24124A133)

26. NRC letter to Southern Nuclear Operating Company dated January 24, 2025, Joseph M. Farley Nuclear Plant, Units 1 and 2, and Edwin I. Hatch Nuclear Plant, Units 1 and 2 -

Issuance of Amendments Regarding Revision to Technical Specifications to Use Online Monitoring Methodology, (ADAMS Accession No. ML24351A080)

27. Pacific Gas and Electric Company letter DCL-24-118 to NRC dated December 31, 2024, License Amendment Request 24-06 Revision to Technical Specification 1.1 and Addition of 5.5.21 to Use Online Monitoring Methodology, (ADAMS Accession No. ML24366A169)

28. NRC letter to Pacific Gas and Electric Company dated August 21, 2025, Diablo Canyon Nuclear Power Plant, Units 1 and 2 - Issuance of Amendment Nos. 253 and 255 RE:

Revision to Technical Specification 1.1 and Addition of Technical Specification 5.5.21 to Use Online Monitoring Methodology, (ADAMS Accession No. ML25230A133)

(QFORVXUHWRRA-24-0273 Brunswick Steam Electric Plant Unit 1 Technical Specification Mark-ups

Definitions 1.1 Brunswick Unit 1 1.1-1 Amendment No. 203 1.0 USE AND APPLICATION 1.1 Definitions

---

NOTE-----------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific planar height HEAT GENERATION RATE and is equal to the sum of the heat generation rate per unit (APLHGR) length of fuel rod for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height.

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. 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 so that the entire channel is calibrated.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

(continued)

INSERT:

(excluding transmitters in the Online Monitoring Program)

Programs and Manuals 5.5 Brunswick Unit 1 5.0-17b Amendment No. 308278 5.5 Programs and Manuals 5.5.15 Risk-Informed Completion Time Program (continued) d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or 2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods used to support Amendment No. 308, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

e.

INSERT:

New TS 5.5.16 here

INSERT 5.5.16 Online Monitoring Program This program provides controls to determine the need for calibration for 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 shall 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. The Online Monitoring Program shall contain a list of transmitters included in the program, determined in accordance with AMS-TR-0720R2-A.

b. Online monitoring evaluation of transmitters in the program shall include the following:

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

c. Performance of calibration checks during the next refueling outage of any transmitters identified as requiring a calibration check or that were not evaluated in accordance with Paragraph b.

d. Performance of calibration checks at the backstop interval determined in accordance with AMS-TR-0720R2-A.

e. Appropriate actions in the event calibration checks are not performed as specified by the program.

(QFORVXUHWRRA-24-0273 Brunswick Steam Electric Plant Unit 1 Technical Specification Bases Mark-ups (Information only)

RPS Instrumentation B 3.3.1.1 Brunswick Unit 1 B 3.3.1.1-36 Revision No. 94 BASES SURVEILLANCE SR 3.3.1.1.13 (continued)

REQUIREMENTS calorimetric calibration (SR 3.3.1.1.3) and the LPRM calibration against the TIPs (SR 3.3.1.1.8).

A second Note is provided that requires the IRM SRs to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering MODE 2 from MODE 1. Testing of the MODE 2 IRM Functions cannot be performed in MODE 1 without utilizing jumpers, lifted leads, or movable links. This Note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR.

A third note is provided that requires that the recirculation flow (drive flow) transmitters, which supply the flow signal to the APRMs, be included in the SR for Functions 2.b and 2.f. The APRM Simulated Thermal Power High Function (Function 2.b) and the OPRM Upscale Function (Function 2.f) both require a valid drive flow signal. The APRM Simulated Thermal PowerHigh Function uses drive flow to automatically enable or bypass the OPRM Upscale trip output to RPS. A CHANNEL CALIBRATION of the APRM drive flow signal requires both calibrating the drive flow transmitters and the processing hardware in the APRM equipment. SR 3.3.1.1.18 establishes a valid drive flow/core flow relationship. Changes throughout the cycle in the drive flow/core flow relationship due to the changing thermal hydraulic operating conditions of the core are accounted for in the margins included in the bases or analyses used to establish the setpoints for the APRM Simulated Thermal PowerHigh Function and the OPRM Upscale Function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.14 (Not used.)

(continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 19).

RPS Instrumentation B 3.3.1.1 Brunswick Unit 1 B 3.3.1.1-38 Revision No. 94 BASES SURVEILLANCE SR 3.3.1.1.16 (continued)

REQUIREMENTS non-bypass condition, this SR is met and the channel is considered OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.17 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. This test may be performed in one measurement or in overlapping segments, with verification that all components are tested. The RPS RESPONSE TIME acceptance criteria are included in Reference 13.

RPS RESPONSE TIME for the APRM 2-Out-Of-4 Voter Function (2.e) includes the output relays of the voter and the associated RPS relays and contactors. (The digital portion of the APRM and 2-Out-Of-4 Voter channels are excluded from RPS RESPONSE TIME testing because self-testing and calibration checks the time base of the digital electronics.

Confirmation of the time base is adequate to assure required response times are met. Neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time.)

Note 2 states the response time of the sensors for Functions 3 and 4 may be assumed in the RPS RESPONSE TIME test to be the design sensor response time. This is allowed since the sensor response time is a small part of the overall RPS RESPONSE TIME (Ref. 14).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Insert:

For transmitters in the Online Monitoring Program, the use of the design sensor response time is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref.

19).

RPS Instrumentation B 3.3.1.1 Brunswick Unit 1 B 3.3.1.1-41 Revision No. 109 BASES REFERENCES

17.

DPC-NE-1009-P, Brunswick Nuclear Plant Implementation of (continued)

Best-estimate Enhanced Option-III, Revision 0, September 2018.

18.

ANP-3703P, BEO-III Analysis Methodology for Brunswick Using RAMONA5-FA, Revision 0, August 2018.

Insert:

19. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 Brunswick Unit 1 B 3.3.2.2-6 Revision No. 94 BASES SURVEILLANCE SR 3.3.2.2.1 (continued)

REQUIREMENTS parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels, or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limits.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.2.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.2.2.3 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the feedwater and main turbine valves is (continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 4).

Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 Brunswick Unit 1 B 3.3.2.2-7 Revision No. 94 BASES SURVEILLANCE SR 3.3.2.2.3 (continued)

REQUIREMENTS included as part of this Surveillance and overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function. Therefore, if a valve is incapable of operating, the associated instrumentation would also be inoperable. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 15.1.2.

2.

10 CFR 50.36(c)(2)(ii).

3.

GENE-770-06-1-A, Bases for Changes to Surveillance Test Intervals and Allowed Out-Of-Service Times for Selected Instrumentation Technical Specifications, December 1992.

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3.1 Brunswick Unit 1 B 3.3.3.1-10 Revision No. 94 BASES SURVEILLANCE SR 3.3.3.1.2 REQUIREMENTS (continued)

Not Used.

SR 3.3.3.1.3 This SR requires a CHANNEL CALIBRATION to be performed.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies the channel responds to measured parameter with the necessary range and accuracy.

For Function 10, the CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr and a one point calibration check of the detector below 10 R/hr with an installed or portable gamma source.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

Regulatory Guide 1.97, Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, December 1980.

2.

NRC Safety Evaluation Report, Conformance to Regulatory Guide 1.97, Rev. 2, Brunswick Steam Electric Plant, Units 1 and 2, May 14, 1985.

3.

10 CFR 50.36(c)(2)(ii).

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 4).

Remote Shutdown Monitoring Instrumentation B 3.3.3.2 Brunswick Unit 1 B 3.3.3.2-4 Revision No. 94 BASES (continued)

SURVEILLANCE SR 3.3.3.2.1 REQUIREMENTS Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. As specified in the Surveillance, a CHANNEL CHECK is only required for those channels that are normally energized. For Function 2 of Table B 3.3.3.2-1, the CHANNEL CHECK requirement does not apply to the N017 instrument loop since this instrument loop has no displayed indication. The CHANNEL CHECK requirement does apply to the remaining instruments of Function 2.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.3.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies the channel responds to measured parameter values with the necessary range and accuracy.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 7.4.4.

2.

10 CFR 50.36(c)(2)(ii).

Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 3).

ATWS-RPT Instrumentation B 3.3.4.1 Brunswick Unit 1 B 3.3.4.1-9 Revision No. 94 BASES SURVEILLANCE SR 3.3.4.1.4 (continued)

REQUIREMENTS CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.1.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers is included as part of this Surveillance and overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the design function. Therefore, if a breaker is incapable of operating, the associated instrument channel(s) would be inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR Sections 5.4.1.2.4 and 7.6.1.3.1.

2.

10 CFR 50.36(c)(2)(ii).

3.

GENE-770-06-1-A, Bases for Changes To Surveillance Test Intervals and Allowed Out-of-Service Times For Selected Instrumentation Technical Specifications, December 1992.

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 4).

ECCS Instrumentation B 3.3.5.1 Brunswick Unit 1 B 3.3.5.1-30 Revision No. 94 BASES SURVEILLANCE SR 3.3.5.1.2 and SR 3.3.5.1.6 (continued)

REQUIREMENTS setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.3.5.1.3 Calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analyses. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.1.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 8).

ECCS Instrumentation B 3.3.5.1 Brunswick Unit 1 B 3.3.5.1-31 Revision No. 94 BASES SURVEILLANCE SR 3.3.5.1.5 REQUIREMENTS (continued)

The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic and simulated automatic operation for a specific channel. The system functional testing performed in LCO 3.5.1, LCO 3.5.2, LCO 3.8.1, and LCO 3.8.2 overlaps this Surveillance to complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 5.2.

2.

UFSAR, Section 6.3.

3.

UFSAR, Chapter 15.

4.

10 CFR 50.36(c)(2)(ii).

5.

(Deleted.)

6.

UFSAR, Section 9.2.6.2.

7.

NEDC-30936-P-A, BWR Owners' Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation), Parts 1 and 2, December 1988.

Insert:

8. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

RCIC System Instrumentation B 3.3.5.2 Brunswick Unit 1 B 3.3.5.2-10 Revision No. 94 BASES SURVEILLANCE SR 3.3.5.2.2 REQUIREMENTS (continued)

A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.2.3 The calibration of trip units provides a check of the actual trip setpoints.

The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.2-1. If the trip setting is discovered to be less conservative than the setting accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.2.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 3).

RCIC System Instrumentation B 3.3.5.2 Brunswick Unit 1 B 3.3.5.2-11 Revision No. 94 BASES SURVEILLANCE SR 3.3.5.2.5 REQUIREMENTS (continued)

The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel and includes simulated automatic actuation of the channel. The system functional testing performed in LCO 3.5.3 overlaps this Surveillance to provide complete testing of the safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

10 CFR 50.36(c)(2)(ii).

2.

GENE-770-06-2P-A, Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications, December 1992.

Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Primary Containment Isolation Instrumentation B 3.3.6.1 Brunswick Unit 1 B 3.3.6.1-30 Revision No. 94 BASES SURVEILLANCE SR 3.3.6.1.4 and SR 3.3.6.1.6 (continued)

REQUIREMENTS CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.3.6.1.7 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel and includes simulated automatic operation of the channel. The system functional testing performed on PCIVs in LCO 3.6.1.3 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.1.8 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.

Testing is performed only on channels where the assumed response time does not correspond to the diesel generator (DG) start time. For channels assumed to respond within the DG start time, sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test (Ref. 9).

(continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 10).

Primary Containment Isolation Instrumentation B 3.3.6.1 Brunswick Unit 1 B 3.3.6.1-31 Revision No. 94 BASES SURVEILLANCE SR 3.3.6.1.8 (continued)

REQUIREMENTS Note 1 to the Surveillance states that the radiation detectors are excluded from ISOLATION INSTRUMENTATION RESPONSE TIME testing. This Note is necessary because of the difficulty of generating an appropriate detector input signal and because the principles of detector operation virtually ensure an instantaneous response time. Response times for radiation detector channels shall be measured from detector output or the input of the first electronic component in the channel. In addition, Note 2 to the Surveillance states that the response time of the sensors for Functions 1.a and 1.c may be assumed to be the design sensor response time and therefore, are excluded from the ISOLATION INSTRUMENTATION RESPONSE TIME testing. This is allowed since the sensor response time is a small part of the overall ISOLATION INSTRUMENTATION RESPONSE TIME (Ref. 9).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 6.3.

2.

UFSAR, Chapter 15.

3.

NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, September 1995.

4.

10 CFR 50.36(c)(2)(ii).

5.

UFSAR, Section 6.2.4.3.

6.

UFSAR, Section 7.3.1.1.6.18.

7.

NEDC-31677P-A, Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation, July 1990.

8.

NEDC-30851P-A Supplement 2, Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation, March 1989.

9.

NEDO-32291-A, System Analyses for Elimination of Selected Response Time Requirements, October 1995.

Insert:

10. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

For transmitters in the Online Monitoring Program, the use of the design sensor response time is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref.

10).

Secondary Containment Isolation Instrumentation B 3.3.6.2 Brunswick Unit 1 B 3.3.6.2-10 Revision No. 94 BASES SURVEILLANCE SR 3.3.6.2.4 REQUIREMENTS (continued)

A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel and includes simulated automatic operation of the channel. The system functional testing performed on SCIDs and the SGT System in LCO 3.6.4.2 and LCO 3.6.4.3, respectively, overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 15.6.4.

2.

Not used.

3.

NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, September 1995.

4.

10 CFR 50.36(c)(2)(ii).

5.

NEDC-31677P-A, Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation, July 1990.

6.

NEDC-30851P-A Supplement 2, Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation, March 1989.

Insert:

7. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 7).

RCS Leakage Detection Instrumentation B 3.4.5 Brunswick Unit 1 B 3.4.5-5 Revision No. 94 BASES (continued)

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR is for the performance of a CHANNEL CHECK of the required primary containment atmosphere radioactivity monitoring system. The check gives reasonable confidence that the channel is operating properly.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.5.2 This SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies, for the radioactivity monitoring channels only, the required alarm function of the instrument string. A source check along with a channel check will be used to determine the relative accuracy of the instrument. Failure of the source check not attributed to an instrument indication problem (e.g., problem with source check mechanism and not the detector), would not immediately result in instrument inoperability. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.5.3 This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 5.2.5.

2.

Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detections Systems," May 1973.

3.

GEAP-5620, Failure Behavior in ASTM A106B Pipes Containing Axial ThroughWall Flaws, April 1968.

4.

NUREG-75/067, Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping in Boiling Water Reactors, October 1975.

5.

UFSAR, Section 5.2.5.2.2.

6.

10 CFR 50.36(c)(2)(ii).

Insert:

7. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 7).

ECCSOperating B 3.5.1 Brunswick Unit 1 B 3.5.1-16 Revision No. 107 BASES SURVEILLANCE SR 3.5.1.11 (continued)

REQUIREMENTS Method 2 A manual actuation of each required ADS valve is performed to verify that the valve and solenoid are functioning properly and that no blockage exists in the SRV discharge lines. This is demonstrated by the response of the turbine control or bypass valve; by a change in the measured flow; or by any other method suitable to verify steam flow. Adequate reactor steam dome pressure must be available to perform this test to avoid damaging the valve. Sufficient time is therefore allowed after the required pressure is achieved to perform this SR. Adequate pressure at which this SR is to be performed, to avoid damaging the valve, is 945 psig. Reactor startup is allowed prior to performing this SR because valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements, prior to valve installation. Therefore, this SR is modified by a Note that states the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the test. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for manual actuation after the required pressure is reached is sufficient to achieve stable conditions and provides adequate time to complete the Surveillance. SR 3.5.1.10 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the INSERVICE TESTING PROGRAM. Industry operating experience has shown that these components usually pass the SR when performed at the Code required Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.5.1.12 This SR ensures that the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is less than or equal to the maximum value assumed in the accident analysis. Response time testing acceptance criteria are included in Reference 13. This SR is modified by a Note that allows the instrumentation portion of the response time to be assumed to be the design instrumentation response time. Therefore, the instrumentation response time is excluded from the ECCS RESPONSE TIME testing. This exception is allowed since the ECCS instrumentation response time is a small part of the ECCS RESPONSE TIME (e.g.,

sufficient margin exists in the emergency diesel generator start time when compared to the instrumentation response time) (Ref. 14).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

For transmitters in the Online Monitoring Program, the use of the design sensor response time is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref.

17).

ECCSOperating B 3.5.1 Brunswick Unit 1 B 3.5.1-17 Revision No. 107 BASES (continued)

REFERENCES

1.

UFSAR, Section 6.3.2.2.3.

2.

UFSAR, Section 6.3.2.2.4.

3.

UFSAR, Section 6.3.2.2.1.

4.

UFSAR, Section 6.3.2.2.2.

5.

UFSAR, Section 15.2.

6.

UFSAR, Section 15.6.

7.

10 CFR 50, Appendix K.

8.

UFSAR, Section 6.3.3.

9.

10 CFR 50.46.

10.

(Deleted.)

11.

10 CFR 50.36(c)(2)(ii).

12.

Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC),

Recommended Interim Revisions to LCOs for ECCS Components, December 1, 1975.

13.

UFSAR, Section 6.3.3.7.

14.

NEDO-32291-A, System Analyses for the Elimination of Selected Response Time Testing Requirements, October 1995.

15.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

16.

ASME Operation and Maintenance (OM) Code.

Insert:

17. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

(QFORVXUHWRRA-24-0273 Brunswick Steam Electric Plant Unit 2 Technical Specification Mark-ups

Definitions 1.1 Brunswick Unit 2 1.1-1 Amendment No. 233 1.0 USE AND APPLICATION 1.1 Definitions

---

NOTE-----------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

AVERAGE PLANAR LINEAR The APLHGR shall be applicable to a specific planar height HEAT GENERATION RATE and is equal to the sum of the heat generation rate per unit (APLHGR) length of fuel rod for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height.

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. 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 so that the entire channel is calibrated.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

(continued)

INSERT:

(excluding transmitters in the Online Monitoring Program)

3URJUDPVDQG0DQXDOV



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$PHQGPHQW1R336

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d.

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5LVN0DQDJHPHQW$FWLRQV50$VQRWDOUHDG\\FUHGLWHGLQWKH 5,&7FDOFXODWLRQVKDOOEHLPSOHPHQWHGWKDWVXSSRUWUHGXQGDQWRU GLYHUVH66&VWKDWSHUIRUPWKHIXQFWLRQVRIWKHLQRSHUDEOH66&V

DQGLISUDFWLFDEOHUHGXFHWKHIUHTXHQF\\RILQLWLDWLQJHYHQWVWKDW FKDOOHQJHWKHIXQFWLRQVSHUIRUPHGE\\WKHLQRSHUDEOH66&V

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods used to support Amendment No. 336, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

e.

INSERT:

New TS 5.5.16 here

INSERT 5.5.16 Online Monitoring Program This program provides controls to determine the need for calibration for 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 shall 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. The Online Monitoring Program shall contain a list of transmitters included in the program, determined in accordance with AMS-TR-0720R2-A.

b. Online monitoring evaluation of transmitters in the program shall include the following:

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

c. Performance of calibration checks during the next refueling outage of any transmitters identified as requiring a calibration check or that were not evaluated in accordance with Paragraph b.

d. Performance of calibration checks at the backstop interval determined in accordance with AMS-TR-0720R2-A.

e. Appropriate actions in the event calibration checks are not performed as specified by the program.

(QFORVXUHWRRA-24-0273 Brunswick Steam Electric Plant Unit 2 Technical Specification Bases Mark-ups (Information only)

RPS Instrumentation B 3.3.1.1 Brunswick Unit 2 B 3.3.1.1-36 Revision No. 94 BASES SURVEILLANCE SR 3.3.1.1.13 (continued)

REQUIREMENTS calorimetric calibration (SR 3.3.1.1.3) and the LPRM calibration against the TIPs (SR 3.3.1.1.8).

A second Note is provided that requires the APRM and IRM SRs to be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering MODE 2 from MODE 1. Testing of the MODE 2 APRM and IRM Functions cannot be performed in MODE 1 without utilizing jumpers, lifted leads, or movable links. This Note allows entry into MODE 2 from MODE 1 if the associated Frequency is not met per SR 3.0.2. Twelve hours is based on operating experience and in consideration of providing a reasonable time in which to complete the SR.

A third note is provided that requires that the recirculation flow (drive flow) transmitters, which supply the flow signal to the APRMs, be included in the SR for Functions 2.b and 2.f. The APRM Simulated Thermal Power High Function (Function 2.b) and the OPRM Upscale Function (Function 2.f) both require a valid drive flow signal. The APRM Simulated Thermal PowerHigh Function uses drive flow to automatically enable or bypass the OPRM Upscale trip output to RPS. A CHANNEL CALIBRATION of the APRM drive flow signal requires both calibrating the drive flow transmitters and the processing hardware in the APRM equipment. SR 3.3.1.1.18 establishes a valid drive flow/core flow relationship. Changes throughout the cycle in the drive flow/core flow relationship due to the changing thermal hydraulic operating conditions of the core are accounted for in the margins included in the bases or analyses used to establish the setpoints for the APRM Simulated Thermal PowerHigh Function and the OPRM Upscale Function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.14 (Not used.)

(continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 19).

RPS Instrumentation B 3.3.1.1 Brunswick Unit 2 B 3.3.1.1-38 Revision No. 94 BASES SURVEILLANCE SR 3.3.1.1.16 (continued)

REQUIREMENTS non-bypass condition, this SR is met and the channel is considered OPERABLE.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.1.17 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. This test may be performed in one measurement or in overlapping segments, with verification that all components are tested. The RPS RESPONSE TIME acceptance criteria are included in Reference 13.

RPS RESPONSE TIME for the APRM 2-Out-Of-4 Voter Function (2.e) includes the output relays of the voter and the associated RPS relays and contactors. (The digital portion of the APRM and 2-Out-Of-4 Voter channels are excluded from RPS RESPONSE TIME testing because self-testing and calibration checks the time base of the digital electronics.

Confirmation of the time base is adequate to assure required response times are met. Neutron detectors are excluded from RPS RESPONSE TIME testing because the principles of detector operation virtually ensure an instantaneous response time.)

Note 2 states the response time of the sensors for Functions 3 and 4 may be assumed in the RPS RESPONSE TIME test to be the design sensor response time. This is allowed since the sensor response time is a small part of the overall RPS RESPONSE TIME (Ref. 14).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Insert:

For transmitters in the Online Monitoring Program, the use of the design sensor response time is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref.

19).

RPS Instrumentation B 3.3.1.1 Brunswick Unit 2 B 3.3.1.1-41 Revision No. 114 BASES REFERENCES

17.

DPC-NE-1009-P, Brunswick Nuclear Plant Implementation of (continued)

Best-estimate Enhanced Option-III, Revision 0, September 2018.

18.

ANP-3703P, BEO-III Analysis Methodology for Brunswick Using RAMONA5-FA, Revision 0, August 2018.

Insert:

19. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 Brunswick Unit 2 B 3.3.2.2-6 Revision No. 94 BASES SURVEILLANCE SR 3.3.2.2.1 (continued)

REQUIREMENTS similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the channels, or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limits.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.2.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.2.2.3 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the feedwater and main turbine valves is (continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 4).

Feedwater and Main Turbine High Water Level Trip Instrumentation B 3.3.2.2 Brunswick Unit 2 B 3.3.2.2-7 Revision No. 94 BASES SURVEILLANCE SR 3.3.2.2.3 (continued)

REQUIREMENTS included as part of this Surveillance and overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the assumed safety function. Therefore, if a valve is incapable of operating, the associated instrumentation would also be inoperable. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 15.1.2.

2.

10 CFR 50.36(c)(2)(ii).

3.

GENE-770-06-1-A, Bases for Changes to Surveillance Test Intervals and Allowed Out-Of-Service Times for Selected Instrumentation Technical Specifications, December 1992.

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3.1 Brunswick Unit 2 B 3.3.3.1-10 Revision No. 94 BASES SURVEILLANCE SR 3.3.3.1.2 REQUIREMENTS (continued)

Not Used.

SR 3.3.3.1.3 This SR requires a CHANNEL CALIBRATION to be performed.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies the channel responds to measured parameter with the necessary range and accuracy.

For Function 10, the CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/hr and a one point calibration check of the detector below 10 R/hr with an installed or portable gamma source.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

Regulatory Guide 1.97, Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Revision 2, December 1980.

2.

NRC Safety Evaluation Report, Conformance to Regulatory Guide 1.97, Rev. 2, Brunswick Steam Electric Plant, Units 1 and 2, May 14, 1985.

3.

10 CFR 50.36(c)(2)(ii).

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 4).

Remote Shutdown Monitoring Instrumentation B 3.3.3.2 Brunswick Unit 2 B 3.3.3.2-4 Revision No. 94 BASES (continued)

SURVEILLANCE SR 3.3.3.2.1 REQUIREMENTS Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. As specified in the Surveillance, a CHANNEL CHECK is only required for those channels that are normally energized. For Function 2 of Table B 3.3.3.2-1, the CHANNEL CHECK requirement does not apply to the NO17 instrument loop since this instrument loop has no displayed indication. The CHANNEL CHECK requirement does apply to the remaining instruments of Function 2.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.3.2.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies the channel responds to measured parameter values with the necessary range and accuracy.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 7.4.4.

2.

10 CFR 50.36(c)(2)(ii).

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 3).

Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

ATWS-RPT Instrumentation B 3.3.4.1 Brunswick Unit 2 B 3.3.4.1-9 Revision No. 94 BASES SURVEILLANCE SR 3.3.4.1.4 (continued)

REQUIREMENTS CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.1.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required trip logic for a specific channel. The system functional test of the pump breakers is included as part of this Surveillance and overlaps the LOGIC SYSTEM FUNCTIONAL TEST to provide complete testing of the design function. Therefore, if a breaker is incapable of operating, the associated instrument channel(s) would be inoperable.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR Sections 5.4.1.2.4 and 7.6.1.3.1.

2.

10 CFR 50.36(c)(2)(ii).

3.

GENE-770-06-1-A, Bases for Changes To Surveillance Test Intervals and Allowed Out-of-Service Times For Selected Instrumentation Technical Specifications, December 1992.

Insert:

4. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 4).

ECCS Instrumentation B 3.3.5.1 Brunswick Unit 2 B 3.3.5.1-30 Revision No. 94 BASES SURVEILLANCE SR 3.3.5.1.2 and SR 3.3.5.1.6 (continued)

REQUIREMENTS setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.3.5.1.3 Calibration of trip units provides a check of the actual trip setpoints. The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.1-1. If the trip setting is discovered to be less conservative than accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analyses. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than the setting accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.1.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 8).

ECCS Instrumentation B 3.3.5.1 Brunswick Unit 2 B 3.3.5.1-31 Revision No. 94 BASES SURVEILLANCE SR 3.3.5.1.5 REQUIREMENTS (continued)

The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic and simulated automatic operation for a specific channel. The system functional testing performed in LCO 3.5.1, LCO 3.5.2, LCO 3.8.1, and LCO 3.8.2 overlaps this Surveillance to complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 5.2.

2.

UFSAR, Section 6.3.

3.

UFSAR, Chapter 15.

4.

10 CFR 50.36(c)(2)(ii).

5.

(Deleted).

6.

UFSAR, Section 9.2.6.2.

7.

NEDC-30936-P-A, BWR Owners' Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation), Parts 1 and 2, December 1988.

Insert:

8. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

RCIC System Instrumentation B 3.3.5.2 Brunswick Unit 2 B 3.3.5.2-10 Revision No. 94 BASES SURVEILLANCE SR 3.3.5.2.2 REQUIREMENTS (continued)

A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the channel will perform the intended function. Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.2.3 The calibration of trip units provides a check of the actual trip setpoints.

The channel must be declared inoperable if the trip setting is discovered to be less conservative than the Allowable Value specified in Table 3.3.5.2-1. If the trip setting is discovered to be less conservative than the setting accounted for in the appropriate setpoint methodology, but is not beyond the Allowable Value, the channel performance is still within the requirements of the plant safety analysis. Under these conditions, the setpoint must be readjusted to be equal to or more conservative than accounted for in the appropriate setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.2.4 A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 3).

RCIC System Instrumentation B 3.3.5.2 Brunswick Unit 2 B 3.3.5.2-11 Revision No. 94 BASES SURVEILLANCE SR 3.3.5.2.5 REQUIREMENTS (continued)

The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel and includes simulated automatic actuation of the channel. The system functional testing performed in LCO 3.5.3 overlaps this Surveillance to provide complete testing of the safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

10 CFR 50.36(c)(2)(ii).

2.

GENE-770-06-2P-A, Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications, December 1992.

Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Primary Containment Isolation Instrumentation B 3.3.6.1 Brunswick Unit 2 B 3.3.6.1-31 Revision No. 94 BASES SURVEILLANCE SR 3.3.6.1.4 and SR 3.3.6.1.6 (continued)

REQUIREMENTS CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequencies are controlled under the Surveillance Frequency Control Program.

SR 3.3.6.1.7 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel and includes simulated automatic operation of the channel. The system functional testing performed on PCIVs in LCO 3.6.1.3 overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.1.8 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis.

Testing is performed only on channels where the assumed response time does not correspond to the diesel generator (DG) start time. For channels assumed to respond within the DG start time, sufficient margin exists in the 10 second start time when compared to the typical channel response time (milliseconds) so as to assure adequate response without a specific measurement test (Ref. 9).

(continued)

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 10).

Primary Containment Isolation Instrumentation B 3.3.6.1 Brunswick Unit 2 B 3.3.6.1-32 Revision No. 94 BASES SURVEILLANCE SR 3.3.6.1.8 (continued)

REQUIREMENTS Note 1 to the Surveillance states that the radiation detectors are excluded from ISOLATION INSTRUMENTATION RESPONSE TIME testing. This Note is necessary because of the difficulty of generating an appropriate detector input signal and because the principles of detector operation virtually ensure an instantaneous response time. Response times for radiation detector channels shall be measured from detector output or the input of the first electronic component in the channel. In addition, Note 2 to the Surveillance states that the response time of the sensors for Functions 1.a, 1.c, and 1.f may be assumed to be the design sensor response time and therefore, are excluded from the ISOLATION INSTRUMENTATION RESPONSE TIME testing. This is allowed since the sensor response time is a small part of the overall ISOLATION INSTRUMENTATION RESPONSE TIME (Ref. 9).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 6.3.

2.

UFSAR, Chapter 15.

3.

NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, September 1995.

4.

10 CFR 50.36(c)(2)(ii).

5.

UFSAR, Section 6.2.4.3.

6.

UFSAR, Section 7.3.1.1.6.18.

7.

NEDC-31677P-A, Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation, July 1990.

8.

NEDC-30851P-A Supplement 2, Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation, March 1989.

9.

NEDO-32291-A, System Analyses for Elimination of Selected Response Time Requirements, October 1995.

Insert:

10. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, the use of the design sensor response time is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref.

10).

Secondary Containment Isolation Instrumentation B 3.3.6.2 Brunswick Unit 2 B 3.3.6.2-10 Revision No. 94 BASES SURVEILLANCE SR 3.3.6.2.4 REQUIREMENTS (continued)

A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. This test verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drifts between successive calibrations consistent with the plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.6.2.5 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required isolation logic for a specific channel and includes simulated automatic operation of the channel. The system functional testing performed on SCIDs and the SGT System in LCO 3.6.4.2 and LCO 3.6.4.3, respectively, overlaps this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 15.6.4.

2.

Not used.

3.

NEDC-32466P, Power Uprate Safety Analysis Report for Brunswick Steam Electric Plant Units 1 and 2, September 1995.

4.

10 CFR 50.36(c)(2)(ii).

5.

NEDC-31677P-A, Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation, July 1990.

6.

NEDC-30851P-A Supplement 2, Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation, March 1989.

Insert:

7. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 7).

RCS Leakage Detection Instrumentation B 3.4.5 Brunswick Unit 2 B 3.4.5-5 Revision No. 94 BASES (continued)

SURVEILLANCE SR 3.4.5.1 REQUIREMENTS This SR is for the performance of a CHANNEL CHECK of the required primary containment atmosphere radioactivity monitoring system. The check gives reasonable confidence that the channel is operating properly.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.5.2 This SR is for the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies, for the radioactivity monitoring channels only, the required alarm function of the instrument string. A source check along with a channel check will be used to determine the relative accuracy of the instrument. Failure of the source check not attributed to an instrument indication problem (e.g., problem with source check mechanism and not the detector), would not immediately result in instrument inoperability. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.5.3 This SR is for the performance of a CHANNEL CALIBRATION of required leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 5.2.5.

2.

Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detections Systems," May 1973.

3.

GEAP-5620, Failure Behavior in ASTM A106B Pipes Containing Axial ThroughWall Flaws, April 1968.

4.

NUREG-75/067, Investigation and Evaluation of Cracking in Austenitic Stainless Steel Piping in Boiling Water Reactors, October 1975.

5.

UFSAR, Section 5.2.5.2.2.

6.

10 CFR 50.36(c)(2)(ii).

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.16, Online Monitoring Program (Ref. 7).

Insert:

7. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

ECCSOperating B 3.5.1 Brunswick Unit 2 B 3.5.1-16 Revision No. 107 BASES SURVEILLANCE SR 3.5.1.11 (continued)

REQUIREMENTS Method 2 A manual actuation of each required ADS valve is performed to verify that the valve and solenoid are functioning properly and that no blockage exists in the SRV discharge lines. This is demonstrated by the response of the turbine control or bypass valve; by a change in the measured flow; or by any other method suitable to verify steam flow. Adequate reactor steam dome pressure must be available to perform this test to avoid damaging the valve. Sufficient time is therefore allowed after the required pressure is achieved to perform this SR. Adequate pressure at which this SR is to be performed, to avoid damaging the valve, is 945 psig. Reactor startup is allowed prior to performing this SR because valve OPERABILITY and the setpoints for overpressure protection are verified, per ASME requirements, prior to valve installation. Therefore, this SR is modified by a Note that states the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the test. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for manual actuation after the required pressure is reached is sufficient to achieve stable conditions and provides adequate time to complete the Surveillance. SR 3.5.1.10 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the INSERVICE TESTING PROGRAM. Industry operating experience has shown that these components usually pass the SR when performed at the Code required Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

SR 3.5.1.12 This SR ensures that the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is less than or equal to the maximum value assumed in the accident analysis. Response time testing acceptance criteria are included in Reference 13. This SR is modified by a Note that allows the instrumentation portion of the response time to be assumed to be the design instrumentation response time. Therefore, the instrumentation response time is excluded from the ECCS RESPONSE TIME testing. This exception is allowed since the ECCS instrumentation response time is a small part of the ECCS RESPONSE TIME (e.g.,

sufficient margin exists in the emergency diesel generator start time when compared to the instrumentation response time) (Ref. 14).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

Insert:

For transmitters in the Online Monitoring Program, the use of the design sensor response time is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref.

17).

ECCSOperating B 3.5.1 Brunswick Unit 2 B 3.5.1-17 Revision No. 107 BASES (continued)

REFERENCES

1.

UFSAR, Section 6.3.2.2.3.

2.

UFSAR, Section 6.3.2.2.4.

3.

UFSAR, Section 6.3.2.2.1.

4.

UFSAR, Section 6.3.2.2.2.

5.

UFSAR, Section 15.2.

6.

UFSAR, Section 15.6.

7.

10 CFR 50, Appendix K.

8.

UFSAR, Section 6.3.3.

9.

10 CFR 50.46.

10.

(Deleted.)

11.

10 CFR 50.36(c)(2)(ii).

12.

Memorandum from R.L. Baer (NRC) to V. Stello, Jr. (NRC),

Recommended Interim Revisions to LCOs for ECCS Components, December 1, 1975.

13.

UFSAR, Section 6.3.3.7.

14.

NEDO-32291-A, System Analyses for the Elimination of Selected Response Time Testing Requirements, October 1995.

15.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

16.

ASME Operation and Maintenance (OM) Code.

Insert:

17. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

(QFORVXUHWRRA-24-0273 Catawba Nuclear Station Technical Specification Mark-ups





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INSERT:

New TS 5.5.18 here

INSERT 5.5.18 Online Monitoring Program This program provides controls to determine the need for calibration for 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 shall 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. The Online Monitoring Program shall contain a list of transmitters included in the program, determined in accordance with AMS-TR-0720R2-A.

b. Online monitoring evaluation of transmitters in the program shall include the following:

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

c. Performance of calibration checks during the next refueling outage of any transmitters identified as requiring a calibration check or that were not evaluated in accordance with Paragraph b.

d. Performance of calibration checks at the backstop interval determined in accordance with AMS-TR-0720R2-A.

e. Appropriate actions in the event calibration checks are not performed as specified by the program.

(QFORVXUHWRRA-24-0273 Catawba Nuclear Station Technical Specification Bases Mark-ups (Information only)

RTS Instrumentation B 3.3.1 BASES Catawba Units 1 and 2 B 3.3.1-49 Revision No. 11 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.9 SR 3.3.1.9 is the performance of a TADOT and the Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification is accomplished during the CHANNEL CALIBRATION.

SR 3.3.1.10 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the setpoint methodology.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. The applicable time constants are shown in Table 3.3.1-1.

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.18, Online Monitoring Program (Ref. 15).

RTS Instrumentation B 3.3.1 BASES Catawba Units 1 and 2 B 3.3.1-51 Revision No. 11 SURVEILLANCE REQUIREMENTS (continued)

For Functions for which TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions (Reference 13) has been implemented, this SR is modified by two Notes as identified in Table 3.3.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.

Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the NOMINAL TRIP SETPOINT (NTSP). Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in the UFSAR. The NOMINAL TRIP SETPOINT definition includes a provision that would allow the as-left setting for the channel to be outside the tolerance band, provided the setting is conservative with respect to the NTSP. This provision is not applicable to Functions for which the second Note applies.

SR 3.3.1.12 SR 3.3.1.12 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

Insert: For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.18, Online Monitoring Program (Ref. 15).

RTS Instrumentation B 3.3.1 BASES Catawba Units 1 and 2 B 3.3.1-54 Revision No. 11 SURVEILLANCE REQUIREMENTS (continued)

WCAP-14036-P-A Revision 1, "Elimination of Periodic Protection Channel Response Time Tests" provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in Ref. 8 and Ref. 9, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Rev. 2, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 14).

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.16 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response. The response time of the neutron flux signal portion of the channel shall be measured from detector output or input of the first electronic component in the channel.

REFERENCES

1. UFSAR, Chapter 7.

2. UFSAR, Chapter 6.

3. UFSAR, Chapter 15.

4. IEEE-279-1971.

5. 10 CFR 50.49.

Insert:

The use of the allocated response time for transmitters in the Online Monitoring Program is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref. 15)

RTS Instrumentation B 3.3.1 BASES Catawba Units 1 and 2 B 3.3.1-55 Revision No. 11 REFERENCES (continued)

6. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

7. WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

8. WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements Sep., 1995.

9. WCAP-14036-P-A Revision 1, Elimination of Periodic Protection Channel Response Time Tests Oct., 1998.

10.10 CFR 50.67.

11.WCAP-14333-P-A, Rev. 1, October 1998.

12.WCAP-15376-P-A, Rev. 1, March 2003.

13. Technical Specification Task Force, Improved Standard Technical Specifications Change Traveler, TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions Revision 4.

14. Attachment 1 to TSTF-569, Rev. 2, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing.

Insert:

15. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

ESFAS Instrumentation B 3.3.2 BASES Catawba Units 1 and 2 B 3.3.2-48 Revision No. 14 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.9 SR 3.3.2.9 is the performance of a CHANNEL CALIBRATION.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable. The applicable time constants are shown in Table 3.3.2-1.

For Functions for which TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions has been implemented, this SR is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the NOMINAL TRIP SETPOINT (NTSP). Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that the methodologies for calculating the as-left and the as-found Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.18, Online Monitoring Program (Ref. 16).

ESFAS Instrumentation B 3.3.2 BASES Catawba Units 1 and 2 B 3.3.2-50 Revision No. 14 SURVEILLANCE REQUIREMENTS (continued)

WCAP-14036-P-A Revision 1, "Elimination of Periodic Protection Channel Response Time Tests" provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in Ref. 8 and Ref. 9, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Rev. 2, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 15).

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 600 psig in the SGs.

SR 3.3.2.11 SR 3.3.2.11 is the performance of a COT on the NSWS Suction Transfer

- Low Pit Level.

A COT is performed on each required channel to ensure the entire channel will perform the intended Function. Setpoints must be found within the Allowable Values specified in Table 3.3.2-1. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

Insert:

The use of the allocated response time for transmitters in the Online Monitoring Program is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref.

16).

ESFAS Instrumentation B 3.3.2 BASES Catawba Units 1 and 2 B 3.3.2-52 Revision No. 14 REFERENCES (continued)

15. to TSTF-569, Rev. 2, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing.

Insert:

16. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3 BASES Catawba Units 1 and 2 B 3.3.3-16 Revision No. 7 SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.3.3 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by two Notes. Note 1 excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." Note 2 describes the calibration methods for the Containment Area - High Range monitor.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

UFSAR Section 1.8.

2.

Regulatory Guide 1.97, Rev. 2.

3.

NUREG-0737, Supplement 1, "TMI Action Items."

4.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.18, Online Monitoring Program (Ref. 5).

Insert:

5. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

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Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.18, Online Monitoring Program (Ref. 2).

Insert:

2. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

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Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.18, Online Monitoring Program (Ref. 3).

LTOP System B 3.4.12 BASES Catawba Units 1 and 2 B 3.4.12-13 Revision No. 6 SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.12.6 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.4.12.7 Each required RHR suction relief valve shall be demonstrated OPERABLE by verifying its RHR suction isolation valves are open and by testing it in accordance with the INSERVICE TESTING PROGRAM.

(Refer to SR 3.4.12.3 for the RHR suction isolation valves Surveillance and for a description of the INSERVICE TESTING PROGRAM.) This Surveillance is only required to be performed if the RHR suction relief valve is being used to meet this LCO.

The RHR suction isolation valves are verified open, with power to the valve operator removed and locked in the removed position, to ensure that accidental closure will not occur. The "locked open in the removed position" power supply must be locally verified in its open position with the power supply to the valve locked in its inactive position. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

10 CFR 50, Appendix G.

2.

Generic Letter 88-11.

3.

UFSAR, Section 5.2 4.

10 CFR 50, Section 50.46.

5.

10 CFR 50, Appendix K.

6.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

7.

Generic Letter 90-06.

8.

ASME, Boiler and Pressure Vessel Code,Section III.

9.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.18, Online Monitoring Program (Ref. 10).

Insert:

10. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

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For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.18, Online Monitoring Program (Ref. 9).

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9. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

(QFORVXUHWRRA-24-0273 McGuire Nuclear Station Technical Specification Mark-ups

(continued)

McGuire Units 1 and 2 1.1-1 Amendment Nos. 184/166 Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

---

NOTE-----------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux signals (AFD) between the top and bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions. 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. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated.

INSERT:

(excluding transmitters in the Online Monitoring Program)

Programs and Manuals 5.5 McGuire Units 1 and 2 5.5-17 Amendment No. 330/309 5.5 Programs and Manuals 5.5.18 Risk-Informed Completion Time Program (continued)

e.

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

INSERT:

New TS 5.5.19 here

INSERT 5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration for 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 shall 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. The Online Monitoring Program shall contain a list of transmitters included in the program, determined in accordance with AMS-TR-0720R2-A.

b. Online monitoring evaluation of transmitters in the program shall include the following:

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

c. Performance of calibration checks during the next refueling outage of any transmitters identified as requiring a calibration check or that were not evaluated in accordance with Paragraph b.

d. Performance of calibration checks at the backstop interval determined in accordance with AMS-TR-0720R2-A.

e. Appropriate actions in the event calibration checks are not performed as specified by the program.

(QFORVXUHWRRA-24-0273 McGuire Nuclear Station Technical Specification Bases Mark-ups (Information only)

RTS Instrumentation B 3.3.1 BASES McGuire Units 1 and 2 B 3.3.1-44 Revision No. 180 SURVEILLANCE REQUIREMENTS (continued)

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the setpoint methodology.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. The applicable time constants are shown in Table 3.3.1-1.

For Functions for which TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions (Reference 12) has been implemented, this SR is modified by two Notes as identified in Table 3.3.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. The performance of these channels will be evaluated under the stations Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition for continued OPERABILITY. The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the Nominal Trip Setpoint (NTSP). Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in the UFSAR. The NOMINAL TRIP SETPOINT definition includes a provision that would allow the as-left setting for the channel to be outside the tolerance band, provided the setting is conservative with respect to the NTSP. This provision is not applicable to Functions for which the second NOTE applies.

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 14).

RTS Instrumentation B 3.3.1 BASES McGuire Units 1 and 2 B 3.3.1-46 Revision No. 180 SURVEILLANCE REQUIREMENTS (continued) be in the UFSAR. The NOMINAL TRIP SETPOINT definition includes a provision that would allow the as-left setting for the channel to be outside the tolerance band, provided the setting is conservative with respect to the NTSP.

This provision is not applicable to Functions for which the second NOTE applies.

SR 3.3.1.12 SR 3.3.1.12 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10. Calibration of the 'T channels is required at the beginning of each cycle upon completion of the precision heat balance. RCS loop 'T values shall be determined by precision heat balance measurements at the beginning of each cycle.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.13 SR 3.3.1.13 is the performance of a COT of RTS interlocks.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.14 SR 3.3.1.14 is the performance of a TADOT of the Manual Reactor Trip and the SI Input from ESFAS. The test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers and Reactor Trip Bypass Breakers. The Reactor Trip Bypass Breaker test shall include testing of the automatic undervoltage trip.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

The SR is modified by a Note that excludes verification of setpoints from the TADOT. The Functions affected have no setpoints associated with them.

Insert: For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 14).

RTS Instrumentation B 3.3.1 BASES McGuire Units 1 and 2 B 3.3.1-48 Revision No. 180 SURVEILLANCE REQUIREMENTS (continued) actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g., vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be either demonstrated by test, or their equivalency to those listed in WCAP-13632-P-A, Revision 2. Any demonstration of equivalency must have been determined to be acceptable by NRC staff review.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in Ref. 8 and Ref. 9, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Rev. 2, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 13).

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.16 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response. The response time of the neutron flux signal portion of the channel shall be measured from detector output or input of the first electronic component in the channel.

Insert:

The use of the allocated response time for transmitters in the Online Monitoring Program is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref.

14).

RTS Instrumentation B 3.3.1 BASES McGuire Units 1 and 2 B 3.3.1-49 Revision No. 180 REFERENCES

1.

UFSAR, Chapter 7.

2.

UFSAR, Chapter 6.

3.

UFSAR, Chapter 15.

4.

IEEE-279-1971.

5.

10 CFR 50.49.

6.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

7.

WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

8.

WCAP 13632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements Sep., 1995.

9.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests Oct., 1998.

10.

WCAP-14333-P-A, Revision 1, October 1998.

11.

WCAP-15376-P-A, Revision 1, March 2003.

12.

Technical Specification Task Force, Improved Standard Technical Specifications Change Traveler, TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions, Revision 4.

13. to TSTF-569, Rev. 2, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)

Response Time Testing.

Insert:

14. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

ESFAS Instrumentation B 3.3.2 BASES McGuire Unit 1 and 2 B 3.3.2-40 Revision No. 180 SURVEILLANCE REQUIREMENTS (continued)

The CHANNEL CALIBRATION may be performed at power or during refueling based on bypass testing capability. Channel unavailability evaluations in References 10 and 11 have conservatively assumed that the CHANNEL CALIBRATION is performed at power with the channel in bypass.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable.

The applicable time constants are shown in Table 3.3.2-1.

For Functions for which TSTF-493, Clarify Application of Setpoint Methodology for LSSS Functions, has been implemented; this SR is modified by two (2)

Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the Nominal Trip Setpoint (NTSP). Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable. The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in the UFSAR.

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 13).

ESFAS Instrumentation B 3.3.2 BASES McGuire Unit 1 and 2 B 3.3.2-42 Revision No. 180 SURVEILLANCE REQUIREMENTS (continued) may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in Ref. 8 and Ref. 9, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Rev. 2, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref.12).

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 900 psig in the SGs.

REFERENCES

1.

UFSAR, Chapter 6.

2.

UFSAR, Chapter 7.

3.

UFSAR, Chapter 15.

4.

IEEE-279-1971.

5.

10 CFR 50.49.

6.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

7.

WCAP-10271-P-A, Supplement 1 and Supplement 2, Rev. 1, May 1986 and June 1990.

8.

WCAP 13632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements Sep., 1995.

9.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests Oct., 1998.

10.

WCAP-14333-P-A, Revision 1, October 1998.

11.

WCAP-15376-P-A, Revision 1, March 2003.

12. to TSTF-569, Rev. 2, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)

Response Time Testing.

8.

WCAP 13632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements Sep., 1995.

9.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests Oct., 1998.

Insert:

The use of the allocated response time for transmitters in the Online Monitoring Program is supported by the performance of the 'noise analysis' technique to detect dynamic failure modes that can affect transmitter response time (Ref.

13).

Insert:

13. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3 BASES McGuire Unit 1 and 2 B 3.3.3-15 Revision No. 177 SURVEILLANCE REQUIREMENTS (continued)

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.

As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized.

The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.3.3.2 Not Used SR 3.3.3.3 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

UFSAR Section 1.8.

2.

Regulatory Guide 1.97, Rev. 2.

3.

NUREG-0737, Supplement 1, "TMI Action Items."

4.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 5).

Insert:

5. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."





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Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 2).

Insert:

2. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

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Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 3).

Insert:

3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

LTOP System B 3.4.12 BASES McGuire Units 1 and 2 B 3.4.12-12 Revision No. 160 SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.12.6 Performance of a COT is required within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing RCS temperature to d 300qF and periodically on each required PORV to verify and, as necessary, adjust its lift setpoint. The COT will verify the setpoint is within the allowed maximum limits. PORV actuation could depressurize the RCS and is not required. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency considers the unlikelihood of a low temperature overpressure event during this time.

A Note has been added indicating that this SR is required to be met 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing RCS cold leg temperature to d 300qF. The test must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering the LTOP MODES.

SR 3.4.12.7 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 11).

LTOP System B 3.4.12 BASES McGuire Units 1 and 2 B 3.4.12-13 Revision No. 160 REFERENCES 1.

10 CFR 50, Appendix G.

2.

Generic Letter 88-11.

3.

ASME, Boiler and Pressure Vessel Code,Section III.

4.

UFSAR, Section 5.2.

5.

10 CFR 50, Section 50.46.

6.

10 CFR 50, Appendix K.

7.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

8.

Generic Letter 90-06.

9.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

10.

Duke letter to NRC, Cold Leg Accumulator Isolation Valves, dated September 8, 1987.

Insert:

11. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

RCS Leakage Detection Instrumentation B 3.4.15 BASES McGuire Units 1 and 2 B 3.4.15-9 Revision No. 170 SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the containment atmosphere particulate radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

SR 3.4.15.3, SR 3.4.15.4, SR 3.4.15.5, and SR 3. 4.15.6 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

10 CFR 50, Appendix A, Section IV, GDC 30.

2.

Regulatory Guide 1.45.

3.

UFSAR, Section 5.2.7.

4.

10 CFR 50.36, Technical Specifications, (c)(2)(ii).

5.

UFSAR, Table 18-1.

6.

McGuire License Renewal Commitments MCS-1274.00-00-0016, Section 4.29, RCS Operational Leakage Monitoring Program.

7. McGuire Safety Evaluation Report, Section 5.2.5.

8. UFSAR, Table 5-30.

Insert:

For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 9).

Insert:

9. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

(QFORVXUHWRRA-24-0273 H.B. Robinson Steam Electric Plant Unit No. 2 Technical Specification Mark-ups

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

(continued)

HBRSEP Unit No. 2 1.1-1 Amendment No. 176

---

NOTE--------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux (AFD) signals between the top and bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the required range and accuracy to known input. The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, interlock, display, and trip functions. 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. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping calibrations or total channel steps so that the entire channel is calibrated.

INSERT:

(excluding transmitters in the Online Monitoring Program)

Programs and Manuals 5.5 5.5 Programs and Manuals HBRSEP Unit No. 2 5.0-22b Amendment No. 265 5.5.18 Surveillance Frequency Control Program (continued) a.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

INSERT:

New TS 5.5.19 here

INSERT 5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration for 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 shall 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. The Online Monitoring Program shall contain a list of transmitters included in the program, determined in accordance with AMS-TR-0720R2-A.

b. Online monitoring evaluation of transmitters in the program shall include the following:

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

c. Performance of calibration checks during the next refueling outage of any transmitters identified as requiring a calibration check or that were not evaluated in accordance with Paragraph b.

d. Performance of calibration checks at the backstop interval determined in accordance with AMS-TR-0720R2-A.

e. Appropriate actions in the event calibration checks are not performed as specified by the program.

(QFORVXUHWRRA-24-0273 0 H.B. Robinson Steam Electric Plant Unit No. 2 Technical Specification Bases Mark-ups (Information only)

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For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 10).

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10. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."



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For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 6).



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6. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."



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For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 2).

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2. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."



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For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 5).

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5. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."



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12. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."



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For transmitters in the Online Monitoring Program, calibration checks are performed in accordance with Technical Specification 5.5.19, Online Monitoring Program (Ref. 3).

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3. AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."