ML26077A075

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Regulatory Audit in Support of Review of License Amendment Request to Revise Technical Specification 1.1 and Add Technical Specs 5.5.20 to Use Online Monitoring Methodology (EPID L-2026-LLA-0027) (Audit Plan)
ML26077A075
Person / Time
Site: Wolf Creek 
(NPF-042)
Issue date: 03/25/2026
From: Samson Lee
Plant Licensing Branch IV
To: Reasoner C
Wolf Creek
Lee S, 301-415-3168
References
EPID L-2026-LLA-0027
Download: ML26077A075 (0)


Text

March 25, 2026 Mr. Cleveland Reasoner Chief Executive Officer and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION, UNIT 1 - REGULATORY AUDIT IN SUPPORT OF REVIEW OF LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 1.1 AND ADD TECHNICAL SPECIFICATION 5.5.20 TO USE ONLINE MONITORING METHODOLOGY (EPID L-2026-LLA-0027)

Dear Mr. Reasoner:

By letter dated February 9, 2026 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML26040A346), Wolf Creek Nuclear Operating Corporation (the licensee) submitted a license amendment request (LAR) for Wolf Creek Generating Station, Unit 1 (Wolf Creek). The proposed amendment would revise Technical Specification (TS) 1.1, Definitions, and add TS 5.5.20, Online Monitoring Program, to use the online monitoring (OLM) methodology.

The licensee proposes to use the OLM methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed amendment is based on the U.S. Nuclear Regulatory Commission (NRC)-approved Analysis and Measurement Services Corporation (AMS) topical report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters, August 2021 (ML21235A493).

The NRC staff has identified the need for a regulatory audit to examine the licensees non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.

The NRC staff will conduct the audit virtually via Teams using a licensee established electronic portal available to NRC staff, with audit meetings to be scheduled as needed. The detailed audit plan is enclosed with this letter.

C. Reasoner If you have any questions, please contact me at 301-415-3168 or via email at Samson.Lee@nrc.gov.

Sincerely,

/RA/

Samson S. Lee, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482

Enclosure:

Audit Plan cc: Listserv

Enclosure REGULATORY AUDIT PLAN TO SUPPORT REVIEW OF LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 1.1 AND ADD TECHNICAL SPECIFICATION 5.5.20 TO USE ONLINE MONITORING METHODOLOGY WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION, UNIT 1 DOCKET NO. 50-482

1.0 BACKGROUND

By letter dated February 9, 2026 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML26040A346), Wolf Creek Nuclear Operating Corporation (the licensee) submitted a license amendment request (LAR) for Wolf Creek Generating Station, Unit 1 (Wolf Creek). The proposed amendment would revise Technical Specification (TS) 1.1, Definitions, and add TS 5.5.20, Online Monitoring Program, to use the online monitoring (OLM) methodology.

The licensee proposes to use OLM methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed amendment is based on the U.S. Nuclear Regulatory Commission (NRC)-approved Analysis and Measurement Services Corporation (AMS) topical report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters, August 2021 (ML21235A493).

The NRC staff from the Office of Nuclear Reactor Regulation (NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures, Revision 6, dated July 31, 2020 (ML19248C539).

2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 2, dated December 30, 2024 (ML24309A281), with exceptions noted within this audit plan.

The NRC staff will perform the audit to support its evaluation of whether the licensees LAR can be approved per Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit. The NRC staffs review will be informed by NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Editions. The audit will assist the NRC staff with understanding the licensees proposed OLM LAR.

3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The NRC staffs objectives of the audit are the following:

Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC staffs understanding of the LAR.

Gain a better understanding of plant design features and their implications for the LAR.

Identify any information needed to enable the NRC staffs evaluation of the technical basis used for this application.

Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.

Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information, Revision 1, dated August 5, 2021 (ML21141A238).

The NRC staff will audit the technical information and methods that the licensee used to determine the impact on the plant, and the licensees evaluation of defense-in-depth.

Information needed to support a safety finding or licensing decision may already be docketed, which can be determined during the audit. Otherwise, it must be submitted under oath and affirmation. The licensee may supplement the LAR with this information. Alternatively, the licensee may respond to an RAI. If needed, RAIs will be developed and transmitted separately in accordance with LIC-115.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC staff will request information and an audit meeting(s) throughout the audit period. The NRC staff will use an audit items list to identify the information (e.g., methodology, process information, and calculations) to be audited. The attachment to this audit plan includes the initial audit items list. Throughout the audit period, the NRC staff will provide the licensee with audit questions and audit-related requests so that the licensee can better prepare for audit discussions with the NRC staff. Any information accessed through the licensees portal will not be held or retained in any way by the NRC staff. The NRC staff requests the licensee to have the requested audit information listed in the audit items list to be readily available and accessible for the NRC staffs review via a web-based portal.

5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff from NRR.

Fredrick O'Brien, NRR, Division of Engineering and External Hazards (DEX)/Instrumentation and Controls Branch (EICB) (email: Fredrick.O'Brien@nrc.gov)

Charles McFeaters, Office of Nuclear Regulatory Research (RES), Division of Engineering (DE), Instrumentation, Controls, and Electrical Engineering Branch (ICEEB)

(email: Charles.McFeaters@nrc.gov)

Tarico Sweat, NRR, Division of Safety Systems (DSS)/Technical Specifications Branch (STSB) (email: Tarico.Sweat@nrc.gov) 6.0 LOGISTICS To support the review schedule communicated to the licensee when the NRC staff accepted the LAR for technical review, audit activities will be performed remotely and virtually using Microsoft Teams, teleconference, and a web-based portal or other virtual meeting space created by the licensee. The NRC staff information requests and communications with the licensee staff will be coordinated through the NRCs licensing project manager.

A desktop audit will take place from approximately April 13, 2026, through June 30, 2026. The NRCs licensing project manager will inform the licensee of the entrance and exit meeting dates when they are established. The NRC staff intends to hold virtual audit meetings to discuss information needs and questions arising from the NRC staffs review of the audited items. The NRC staff may change and/or add audit dates and times, or extend the audit, if necessary. The audit meeting agenda and questions, if needed, will be sent in advance of the audit meeting.

The NRC staff requests the licensee to have the information identified in the initial audit items list in the attachment to this audit plan available and accessible for the NRC staffs review via an internet-based portal. The NRC staff requests that responses to subsequent audit questions and audit-related requests to this audit plan be available and accessible for the NRC staffs review within 5 days of the date of the NRCs notification to the licensee of such requests. The NRC staff requests the licensee to notify the NRCs licensing project manager when an audit item is added to its portal by sending an email to the NRC licensing project manager. The NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal.

7.0 SPECIAL REQUESTS The NRC staff requests access to requested documents and information through a web-based portal that allows the NRC staff to access documents over the Internet. The following conditions associated with the online portal must be maintained while the NRC staff has access to the online portal:

The online portal will be password-protected. A separate password will be assigned to each member of the NRC staff participating in the audit.

The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.

Username and password and/or other web-based portal access information should be provided directly to members of the NRC staff as needed. The NRC licensing project manager will provide the licensee with names and contact information of the NRC staff participating in the audit. All other communications should be coordinated through the NRC project manager.

8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, and issue such RAIs separately from audit-related correspondence. The NRC staff will issue an audit summary report prior to completing its review of the LAR.

Attachment:

Initial Audit Items List

Attachment INITIAL AUDIT ITEMS LIST Item #

Audit Item 1

Analysis and Measurement Services Corporation (AMS) Report WFC2404R0, OLM

[Online Monitoring] Amenable Transmitters Report for Wolf Creek 2

AMS Report WFC2405R0, OLM Analysis Methods and Limits Report for Wolf Creek 3

AMS Report WFC2406R0, OLM Drift Monitoring Implementation Report for Wolf Creek 4

AMS Report WFC2407R0, OLM Noise Analysis Program for Wolf Creek

C. Reasoner

SUBJECT:

WOLF CREEK GENERATING STATION, UNIT 1 - REGULATORY AUDIT IN SUPPORT OF REVIEW OF LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 1.1 AND ADD TECHNICAL SPECIFICATION 5.5.20 TO USE ONLINE MONITORING METHODOLOGY (EPID L-2026-LLA-0027) DATED MARCH 25, 2026 DISTRIBUTION:

PUBLIC RidsACRS_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMWolfCreek Resource RidsNrrLAPBlechman Resource RidsNrrDexEicb Resource RidsNrrDssStsb Resource RidsRgn4MailCenter Resource FO'Brien, NRR CMcFeaters, RES TSweat, NRR ADAMS Accession Nos.:

Package: ML26077A077 ML26077A075 (Audit Plan) e-Concurrence Case: 20260318-10003