ML26040A346

License Amendment Request to Revise Technical Specification 1.1 and Add 5.5.20 to Use Online Monitoring Methodology

ML26040A346
Person / Time
Site:	Wolf Creek
Issue date:	02/09/2026
From:	Bayer R Wolf Creek
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
001227
Download: ML26040A346 (0)

Text

P.O. Box 411 l Burlington, KS 66839 l 620-364-8831 Robert J. Bayer Vice President Engineering February 9, 2026 001227 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Docket No. 50-482: License Amendment Request to Revise Technical Specification 1.1 and Add 5.5.20 to Use Online Monitoring Methodology Commissioners and Staff:

Pursuant to 10 CFR 50.90, Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests approval of the enclosed proposed amendment to Wolf Creek Generating Station (WCGS)

Technical Specification (TS) 1.1 Definitions and 5.5 Programs and Manuals.

The proposed amendment revises the TS Section 1.1 Definitions section and adds a new Online Monitoring Program to the Section 5.5 programs section. WCNOC proposes to use the Analysis and Measurement Services Corporation (AMS) online monitoring (OLM) methodology as the technical basis to change from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.

Approval of the proposed amendment is requested by August 31, 2026, to support use during the next refueling outage. Once approved, the amendment will be implemented within 90 days.

In accordance with site administrative procedures and the Quality Assurance Program, the proposed amendment has been reviewed by the Plant Safety Review Committee.

Pursuant to 10 CFR 50.91(b)(1), WCNOC is notifying the State of Kansas of this License Amendment Request by transmitting a copy of this letter and its enclosure to the Director of the Radiation Control Program at the Kansas Department of Health and Environment.

The enclosure to this letter contains the evaluation of the proposed change.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4015, or Dustin Hamman at (620) 364-4204.

(Continued on next page)

001227 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on February 9, 2026.

Sincerely, Robert J. Bayer RJB/nwl

Enclosure:

Evaluation of Proposed Change cc:

A. N. Agrawal (NRC), w/e S. S. Lee (NRC), w/e J. D. Monninger (NRC), w/e Senior Resident Inspector (NRC), w/e WCNOC Licensing Correspondence ET 26-001227, w/e Jason Meinholdt (KDHE), w/e

Enclosure to 001227 Page 1 of 21 Enclosure Evaluation of Proposed Change

Enclosure to 001227 Page 2 of 21 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 TR

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria

4.2 Precedents

4.3 No Significant Hazards Consideration Determination Analysis 4.4 Conclusions

5.

ENVIRONMENTAL CONSIDERATION

6.

REFERENCES ATTACHMENTS:

1.

Wolf Creek Generating Station Technical Specification Mark-ups

2.

Wolf Creek Generating Station Technical Specification Clean Typed

3.

Wolf Creek Generating Station Technical Specification Bases Mark-ups (Information Only)

Enclosure to 001227 Page 3 of 21

1.

SUMMARY

DESCRIPTION Pursuant to the provisions Section 50.90 of Title 10 Code of Federal Regulations (CFR), Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests a license amendment to the Wolf Creek Generating Station (WCGS) Renewed License No. NPF-42. The proposed amendment revises Definitions and adds a new Online Monitoring Program. WCNOC proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results 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 frequency of pressure, level, and flow transmitters to a condition-based calibration frequency 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.

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.

Enclosure to 001227 Page 4 of 21 2.2 System Design and Operation The transmitters evaluated for inclusion 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, Reactor Coolant System (RCS) Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits, Low Temperature Overpressure Protection (LTOP), RCS Operational Leakage, 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 and related systems initiate 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 and related instrumentation are 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 Remote Shutdown System 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 Remote Shutdown System instrumentation is addressed in TS Table 3.3.4-1, Remote Shutdown System Functions.

The RCS Pressure, Temperature, and Flow 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 Technical Specification for RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits is TS 3.4.1.

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

The Pressure and Temperature Limits Report (PTLR) provides the limiting combinations for pressure and temperature to meet 10 CFR 50 Appendix G requirements during the LTOP Modes.

The LTOP ensures that the PTLR limits will not be violated. The LTOP instrumentation is identified in TS 3.4.12, Low Temperature Overpressure Protection (LTOP) System.

RCS Operational Leakage is monitored through an RCS water inventory balance. Although the surveillances associated with TS 3.4.13, RCS Operational Leakage, do not include a

Enclosure to 001227 Page 5 of 21 surveillance for Channel Calibration, some inputs originate from transmitters that are part of RTS and ESFAS.

The RCS Leakage Detection Instrumentation provides the means for detecting RCS leakage. The containment sump level and flow monitoring system used to collect unidentified leakage and the containment cooler condensate monitoring system are instrumented to alarm for increases above the normal fill rates. The RCS Leakage Detection Instrumentation is identified in TS 3.4.15, RCS Leakage Detection Instrumentation. Based on initial reviews, the configuration of WCGS does not currently support including instruments in the RCS Leakage Detection system within the online monitoring program. Since the Technical Specification Surveillance Frequency is controlled through the Surveillance Frequency Control Program, the site may incorporate appropriate transmitters into the online monitoring program in the future through an NRC approved change process, such as 10 CFR 50.59.

The RTS, ESFAS, PAM, Remote Shutdown System, LTOP, RCS Operational Leakage, RCS Leakage Detection Instrumentation, and RCS Pressure, Temperature, and Flow DNB Limits 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 can be found in AMS report WFC2404R0, "OLM Amenable Transmitters Report for Wolf Creek (Reference 3).

Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plant. The changes will not impact how the plant operates. WCNOC will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Implementation of the OLM Program will not result in the change of any calibration methodology.

2.3 Reason for the Proposed Change WCNOC 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 or 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 WCNOC proposes to change the WCGS definitions of CHANNEL CALIBRATION, ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME, and REACTOR TRIP SYSTEM (RTS)

RESPONSE TIME in WCGS TS 1.1 Definitions.

Enclosure to 001227 Page 6 of 21 Current definition of CHANNEL CALIBRATION CHANNEL CALIBRATION - A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. 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.

Proposed definition of CHANNEL CALIBRATION CHANNEL CALIBRATION - A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

Current definition of ESF RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed definition ESF RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

Current definition of RTS RESPONSE TIME The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for

Enclosure to 001227 Page 7 of 21 verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed definition of RTS RESPONSE TIME The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

WCNOC proposes to add a new Online Monitoring Program TS 5.5.20 for WCGS, as shown below.

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

The Online Monitoring Program 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. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items c and d above.

Enclosure to 001227 Page 8 of 21

3.

TECHNICAL EVALUATION 3.1 OLM Implementation Process Development This section describes the steps that were performed to implement the OLM program for WCGS by following the steps identified in AMS-TR-0720R2-A Section 11.1.1. This work is documented in the AMS reports on OLM Amenable Transmitters (Reference 3) and OLM Analysis Methods and Limits (Reference 4).

The AMS report on OLM Amenable Transmitters addresses 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 RTS, ESFAS, PAM, Remote Shutdown System, LTOP, RCS Operational Leakage Detection, and RCS Pressure, Temperature, and Flow DNB Limits transmitters to be included in the OLM program and the bases for their selection can be found in the AMS report 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 the data 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 describes a process to determine the minimum sampling rate for OLM data acquisition to monitor

Enclosure to 001227 Page 9 of 21 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 report on OLM Analysis Methods and Limits (Reference 4) addresses 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 provides the OLM Limit calculations for the transmitters that are amenable to OLM at WCGS.

3.2 OLM Program Implementation This section summarizes the steps that must be followed to implement the OLM program for transmitter drift monitoring at WCGS in accordance with AMS-TR-0720R2-A. The steps described in this section are repeated at each operating cycle at WCGS 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 are contained in the AMS report on OLM Drift Monitoring Program (Reference 5).

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 5

Plot the Average Deviation for Each Transmitter 13 3.2.5

Enclosure to 001227 Page 10 of 21 Item Step Step Number in Section 11.1.2 of AMS-TR-0720R2-A LAR Section 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 WCGS 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 a text files from the data historian or other data sources at the 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 6).

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 7).

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, including the following:

Enclosure to 001227 Page 11 of 21

1. Calculate the process estimate,

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 14 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 16 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

Enclosure to 001227 Page 12 of 21 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 WCGS are described in LAR Section 3.3.

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 Some licensees have 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 in this document to enable licensees to assess the dynamic failure modes of transmitters that are not covered by the OLM process for transmitter drift monitoring.

This section summarizes the steps that must be followed to implement the noise analysis technique for transmitter dynamic failure mode assessment at WCGS in accordance with AMS-TR-0720R2-A. Additional details regarding the implementation of the noise analysis technique discussed in this section are provided in the AMS report on Noise Analysis Program (Reference 8).

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 WCGS, the transmitters with response time requirements have been identified in AMS report on OLM Amenable Transmitters (Reference 3).

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

Enclosure to 001227 Page 13 of 21 Item Step Step Number in Section 11.3.3 of AMS-TR-0720R2-A LAR Section 5

Perform Data Analysis 5

3.3.5 6

Review and Document Results 6

3.3.6 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 WCGS 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, is used for the connection of the noise data acquisition equipment for performing noise analysis testing (Reference 9). 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 V&V 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 9).

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 10) 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

Enclosure to 001227 Page 14 of 21 detailed steps for performing noise data analysis are also provided in the AMS procedure for performing noise analysis data analysis (Reference 10).

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 10).

3.4 Application Specific Action Items (ASAI) 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.

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 WCGS Technical Specifications are identified in Section 2.4 and shown in Attachments 1 and 2. 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

Enclosure to 001227 Page 15 of 21 If the plant has eliminated requirements for performing periodic RT 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: WCGS 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. WCGS proposes 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.

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 the potential that a process group could be experiencing undetected common mode drift characteristics.

Response to ASAI 4: The WCNOC OLM program for WCGS adopts the calibration surveillance interval backstop methods described in Section 3.2.9, which is based on the backstop methodology described in Section 13 of the AMS OLM TR.

The Updated Safety Analysis Report (USAR) for WCGS will be modified to add the use of AMS-TR-0720R2-A to the appropriate parts of Chapters 3 and 7. The use of OLM 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 USAR Chapter 7, including a list of transmitters included in the OLM program. The appropriate parts of USAR Chapter 7 will also be changed 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 WCNOC OLM program for WCGS adopts 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

Enclosure to 001227 Page 16 of 21 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.

WCNOC proposes to use the AMS OLM methodology for WCGS as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency 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 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.

WCNOC proposes to use the AMS OLM methodology for WCGS as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency 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, 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.

WCNOC proposes to use the AMS OLM methodology as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency 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

Enclosure to 001227 Page 17 of 21 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.

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.

WCNOC proposes to use the AMS OLM methodology for WCGS as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on the 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.

WCNOC proposes to use the AMS OLM methodology for WCGS as the technical basis to support plant-specific Technical Specification changes to switch from time-based surveillance frequency

Enclosure to 001227 Page 18 of 21 for channel calibrations to a condition-based calibration frequency based on the OLM results for a given transmitter.

4.2 Precedents The WCNOC license amendment request is based the NRC-approved Analysis and Measurement Services Corporation Topical Report AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (References 1 and 2). Five precedents were identified:

1. NRC approved a 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-A (References 11 and 12).

2. NRC approved a 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-A (References 13 and 14).

3. NRC approved a 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-A (References 15 and 16).

4. NRC approved a license amendment request submitted by Tennessee Valley Authority for Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2-A (References 17 and 18).

5. NRC approved a license amendment request submitted by Entergy for Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1, River Bend Station, Unit 1, and Waterford Steam Electric Station, Unit 3, to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2-A (References 19 and 20).

4.3 No Significant Hazards Consideration Determination Analysis WCNOC has evaluated the proposed changes to the WCGS 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:

WCGS TS 1.1 definitions for CHANNEL CALIBRATION, ESF RESPONSE TIME, and RTS RESPONSE TIME.

The proposed changes add new Online Monitoring Program TSs, as shown below:

WCGS TS 5.5.20 Online Monitoring Program WCNOC proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the

Enclosure to 001227 Page 19 of 21 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 WCNOC 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 The proposed change uses online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency 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 changes do not adversely affect accident initiators or precursors, and do not alter the design assumptions, conditions, or configuration of the plant or the way the plant is operated or maintained.

Therefore, the proposed changes do 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.

Enclosure to 001227 Page 20 of 21 4.4 Conclusions In conclusion, based on the considerations discussed above, WCNOC concludes: (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, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need 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 be prepared in connection with the issuance of the amendment.

6.

REFERENCES

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 WFC2404R0, "OLM Amenable Transmitters Report for Wolf Creek

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

5. AMS Report WFC2406R0, OLM Drift Monitoring Implementation Report for Wolf Creek

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

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

8. AMS Report WFC2407R0, OLM Noise Analysis Program for Wolf Creek

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

Enclosure to 001227 Page 21 of 21

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

11. 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)

12. 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)

13. Southern Nuclear Operating Company letter NL-22-0764 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)

14. 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)

15. 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)

16. 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)

17. Tennessee Valley Authority letter CNL-24-014 to NRC dated November 4, 2024, License Amendment Request to Revise the Sequoyah Nuclear Plant, Units 1 and 2 and Watts Bar Nuclear Plant, Units 1 and 2 Technical Specifications to Use Online Monitoring Methodology (SQN-TS-24-02 and WBN-TS-23-22),

(ADAMS Accession No.

ML24309A061)

18. NRC letter to Tennessee Valley Authority dated December 9, 2025, Sequoyah Nuclear Plant, Units 1 and 2; and Watts Bar Nuclear Plant, Units 1 and 2 - Issuance of Amendment Nos. 373, 368; 177, and 82 Regarding Use of Online Monitoring Methodology, (ADAMS Accession No. ML25328A120)

19. Entergy letter CNRO2024-00002 dated December 4, 2024, Application to Revise Technical Specifications to Use Online Monitoring Methodology, (ADAMS Accession No. ML24339B304)

20. NRC letter to Entergy dated January 21, 2026, Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1, River Bend Station, Unit 1, and Waterford Steam Electric Station, Unit 3 - Issuance of Amendments Related To Revision of Technical Specifications to Use Online Monitoring Methodology. (ADAMS Accession No. ML26007A265)

Enclosure to 001227 Wolf Creek Generating Station Technical Specification Mark-ups (6 Pages)

Definitions 1.1 Wolf Creek - Unit 1 1.1-1 Amendment No. 123 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 required for OPERABILITY of a logic circuit 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 an excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. 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.

(continued)

Enclosure to 001227, Page 2 of 6 INSERT:

(excluding transmitters in the Online Monitoring Program)

Definitions 1.1 Wolf Creek - Unit 1 1.1-3 Amendment No. 123, 131, 170, 221, 236, 243 1.1 Definitions (continued)

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-87, Kr-88, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using the effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil.

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

LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE 1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff); that is captured and conducted to collection systems or a sump or collecting tank; 2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or 3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

(continued)

Enclosure to 001227, Page 3 of 6 INSERT:

(including transmitters in the Online Monitoring Program)

Definitions 1.1 Wolf Creek - Unit 1 1.1-5 Amendment No. 123, 170, 180, 221, 243 1.1 Definitions (continued)

PRESSURE AND The PTLR is the unit specific document that provides the TEMPERATURE LIMITS reactor vessel pressure and temperature limits, including REPORT (PTLR) heatup and cooldown rates and the power operated relief valve lift settings and the Low Temperature Overpressure Protection (LTOP) System arming temperature, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6.

QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore RATIO (QPTR) detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of 3565 MWt.

REACTOR TRIP The RTS RESPONSE TIME shall be that time interval from SYSTEM (RTS) RESPONSE when the monitored parameter exceeds its RTS trip setpoint TIME at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the hot zero power temperatures.

(continued)

Enclosure to 001227, Page 4 of 6 INSERT:

(including transmitters in the Online Monitoring Program)

Programs and Manuals 5.5 Wolf Creek - Unit 1 5.0-23 Amendment No. 123, 142, 152, 164, 179, 227 5.5 Programs and Manuals 5.5.18 Control Room Envelope Habitability Program (continued) e.

The quantitative limits on unfiltered air inleakage into the CRE and CBE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE and CBE unfiltered inleakage, and measuring CRE pressure and assessing the CRE and CBE as required by paragraphs c and d, respectively.

5.5.19 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

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 Technical Specifications Initiative 5b, 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.

Enclosure to 001227, Page 5 of 6 INSERT:

New TS 5.5.20 here

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

The Online Monitoring Program 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.

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

INSERT Enclosure to 001227, Page 6 of 6 INSERT

Enclosure to 001227 Wolf Creek Generating Station Technical Specification Clean Typed (6 Pages)

Definitions 1.1 Wolf Creek - Unit 1 1.1-1 Amendment No. 123, TBD 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 required for OPERABILITY of a logic circuit 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 an excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

(continued)

Definitions 1.1 Wolf Creek - Unit 1 1.1-3 Amendment No. 123, 131, 170, 221, 236, 243, TBD 1.1 Definitions (continued)

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-87, Kr-88, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using the effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil.

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

LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE 1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff); that is captured and conducted to collection systems or a sump or collecting tank; 2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or 3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

(continued)

Definitions 1.1 Wolf Creek - Unit 1 1.1-5 Amendment No. 123, 170, 180, 221, 243, TBD 1.1 Definitions (continued)

PRESSURE AND The PTLR is the unit specific document that provides the TEMPERATURE LIMITS reactor vessel pressure and temperature limits, including REPORT (PTLR) heatup and cooldown rates and the power operated relief valve lift settings and the Low Temperature Overpressure Protection (LTOP) System arming temperature, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.6.

QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper excore RATIO (QPTR) detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to the (RTP) reactor coolant of 3565 MWt.

REACTOR TRIP The RTS RESPONSE TIME shall be that time interval from SYSTEM (RTS) RESPONSE when the monitored parameter exceeds its RTS trip setpoint TIME at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and

b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the hot zero power temperatures.

(continued)

Programs and Manuals 5.5 Wolf Creek - Unit 1 5.0-23 Amendment No. 123, 142, 152, 164, 179, 227, TBD 5.5 Programs and Manuals 5.5.18 Control Room Envelope Habitability Program (continued) e.

The quantitative limits on unfiltered air inleakage into the CRE and CBE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE and CBE unfiltered inleakage, and measuring CRE pressure and assessing the CRE and CBE as required by paragraphs c and d, respectively.

5.5.19 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

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 Technical Specifications Initiative 5b, 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.

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

(continued)

Programs and Manuals 5.5 Wolf Creek - Unit 1 5.0-24 Amendment No. TBD 5.5 Programs and Manuals 5.5.20 Online Monitoring Program (continued)

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.

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

Enclosure to 001227 Wolf Creek Generating Station Technical Specification Bases Mark-ups (Information Only)

(17 Pages)

RTS Instrumentation B 3.3.1 Wolf Creek - Unit 1 B 3.3.1-53 Revision 89 BASES SURVEILLANCE SR 3.3.1.8 (continued)

REQUIREMENTS delay to perform the testing required by this surveillance. The Frequency specified in the Surveillance Frequency Control Program applies if the plant remains in the MODE of Applicability after the initial performances of prior to reactor startup, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reducing power below P-10, and four hours after reducing power below P-6. The MODE of Applicability for this surveillance is < P-10 for the power range low and intermediate range channels and < P-6 for the source range channels. Once the unit is in MODE 3, this surveillance is no longer required. If power is to be maintained < P-10 for more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or < P-6 for more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, then the testing required by this surveillance must be performed prior to the expiration of the 12-hour or the 4-hour limit. These time limits are reasonable, based on operating experience to complete the required testing or place the unit in a MODE where this surveillance is no longer required. This test ensures that the NIS source, intermediate, and power range channels are OPERABLE prior to taking the reactor critical and after reducing power into the applicable MODE (< P-10 or < P-6) for the periods discussed above. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.9 SR 3.3.1.9 is the performance of a TADOT. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This 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 requires elaborate bench calibration and 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 controlled under the Surveillance Frequency Control Program.

Enclosure to 001227, Page 2 of 17 INSERT B 3.3.1-53a

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 12) and TS 5.5.20, Online Monitoring Program.

Enclosure to 001227, Page 3 of 17 B 3.3.1-53a INSERT

RTS Instrumentation B 3.3.1 Wolf Creek - Unit 1 B 3.3.1-56 Revision 97 BASES SURVEILLANCE SR 3.3.1.16 (continued)

REQUIREMENTS channels with response times listed as N.A. No response time testing requirements apply where N.A. is listed in Table B 3.3.1-2. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor until loss of stationary gripper coil voltage.

For channels that include dynamic transfer Functions (e.g., lag, lead/lag, rate/lag, etc.), the response time verification is performed with the time constants set at their nominal values. The response time may be measured by a series of overlapping tests, or other verification (e.g.,

Ref. 7), such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated response times with actual response time tests on the remainder of the channel. Allocations for response times may be obtained from: (1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) inplace, 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 (Ref. 7), 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 demonstrated by test.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, (Ref. 14) 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. 6 and Ref. 14, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Enclosure to 001227, Page 4 of 17 Insert B 3.3.1-56a

Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

Enclosure to 001227, Page 5 of 17 B 3.3.1-56a INSERT

RTS Instrumentation B 3.3.1 Wolf Creek - Unit 1 B 3.3.1-57 Revision 97 BASES SURVEILLANCE SR 3.3.1.16 (continued)

REQUIREMENTS Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 15).

The Surveillance Frequency 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. Response time of the neutron flux signal portion of the channel shall be measured from detector output or input to the first electronic component in the channel.

REFERENCES 1.

USAR, Chapter 7.

2.

USAR, Chapter 15.

3.

IEEE-279-1971.

4.

10 CFR 50.49.

5.

WCNOC Nuclear Safety Analysis Setpoint Methodology for the Reactor Protection System, (TR-89-0001).

6.

WCAP-13632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, January 1996.

7.

WCAP-9226, Reactor Core Response to Excessive Secondary Steam Releases, Revision 1, January 1978.

8.

IE Information Notice 79-22, Qualification of Control Systems, September 14, 1979.

9.

Wolf Creek Setpoint Methodology Report, SNP(KG)-492, August 29, 1984.

10.

USAR, Table 15.0-4.

11.

WCAP-14333-P-A, Revision 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

Enclosure to 001227, Page 6 of 17 Insert B 3.3.1-57a

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

Enclosure to 001227, Page 7 of 17 B 3.3.1-57a INSERT

ESFAS Instrumentation B 3.3.2 Wolf Creek - Unit 1 B 3.3.2-49 Revision 89 BASES SURVEILLANCE SR 3.3.2.9 (continued)

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

This SR is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. This does not include verification of time delay relays.

These are verified by response time testing per SR 3.3.2.10.

SR 3.3.2.10 This SR verifies the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.

Response Time verification acceptance criteria are included in Table B 3.3.2-2. Table B 3.3.2-2 format is based on the initiating trip signal. No credit was taken in the safety analyses for those channels with response times listed as N.A. No response time testing requirements apply where N.A. is listed in Table B 3.3.2-2. Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position).

For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time verification is performed with the time constants set at their nominal values. The response time may be verified by a series of overlapping tests, or other verification (e.g., Ref. 8), such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor response times with 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) inplace, 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 (Ref. 7), provides the basis and methodology for using allocated sensor Enclosure to 001227, Page 8 of 17 Insert B 3.3.2-49a

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 17) and TS 5.5.20, Online Monitoring Program.

Enclosure to 001227, Page 9 of 17 B 3.3.2-49a INSERT

ESFAS Instrumentation B 3.3.2 Wolf Creek - Unit 1 B 3.3.2-50 Revision 97 BASES SURVEILLANCE SR 3.3.2.10 (continued)

REQUIREMENTS 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 demonstrated by test.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, (Ref. 15) 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. 15, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 16).

The NRC approved the use of ASME Code Case OMN-1, Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Plants, as an alternative to stroke time testing for motor-operated valves (Ref. 14). The parameters that must be present to achieve the analyzed response time under design basis conditions are measured to ensure the valve is capable of performing its safety function. This process verifies design basis capability, including response time, and is a significant improvement over simple stroke time measurement. This process allows the establishment of periodic valve test intervals if there is assurance that the valve will remain capable of performing its safety function throughout the interval.

ESF response times specified in Table B 3.3.2-2 which include sequential operation of RWST and VCT valves (Notes 3 and 4) are based on values assumed in the non-LOCA safety analyses. These analyses take credit for injection of borated water from the RWST. Injection of borated water is assumed not to occur until the VCT charging pump suction valves are closed following opening of the RWST charging pump suction valves.

Enclosure to 001227, Page 10 of 17 Insert B 3.3.2-50a

Alternately, the use of the allocated ESF RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

Enclosure to 001227, Page 11 of 17 B 3.3.2-50a INSERT

ESFAS Instrumentation B 3.3.2 Wolf Creek - Unit 1 B 3.3.2-52 Revision 97 BASES REFERENCES 1.

USAR, Chapter 6.

2.

USAR, Chapter 7.

3.

USAR, Chapter 15.

4.

IEEE-279-1971.

5.

10 CFR 50.49.

6.

WCNOC Nuclear Safety Analysis Setpoint Methodology for the Reactor Protection System, TR-89-0001.

7.

WCAP-10271-P-A Supplement 2, Revision 1, "Evaluation of Surveillance Frequencies and Out of Service Times for the Engineered Safety Features Actuation System," June 1990.

8.

WCAP-13632-P-A, Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, January 1996.

9.

Wolf Creek Setpoint Methodology Report, SNP (KG)-492, August 29, 1984.

10.

Amendment No. 43 to Facility Operating License No. NPF-42, March 29, 1991.

11.

WCAP-14333-P-A, Revision 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

12.

10 CFR 50.55a(b)(3)(iii), Code Case OMN-1.

13.

Performance Improvement Request (PIR) 2005-2067.

14.

Amendment No. 231 to Renewed Facility Operating License No.

NPF-42, February 23, 2022.

15.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, December 1995.

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

Response Time Testing.

Enclosure to 001227, Page 12 of 17 Insert:

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

PAM Instrumentation B 3.3.3 Wolf Creek - Unit 1 B 3.3.3-14 Revision 89 BASES SURVEILLANCE SR 3.3.3.1 (continued)

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

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

SR 3.3.3.2 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measure parameter with the necessary range and accuracy. This SR is modified by a Note that excludes neutron detectors. Containment Radiation Level (High Range) CHANNEL CALIBRATION may 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. Whenever an RTD is replaced in Functions 2 or 3, the next required CHANNEL CALIBRATION of the RTD's is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. Whenever a core exit thermocouple is replaced in Functions 14, 15, 16, or 17, the next required CHANNEL CALIBRATION of the core exit thermocouples is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

REFERENCES 1.

USAR Appendix 7A.

2.

Regulatory Guide 1.97, Rev. 2, December 1980.

3.

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

4.

USAR Figure 5.1-1 (sheet 4).

5.

NA 94-0089 dated May 24, 1994.

Enclosure to 001227, Page 13 of 17 Insert:

The Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 11) and TS 5.5.20, Online Monitoring Program.

PAM Instrumentation B 3.3.3 Wolf Creek - Unit 1 B 3.3.3-15 Revision 8 BASES REFERENCES

6.

USAR Section 18.2.13.

(continued)

7.

NUREG-0881, Wolf Creek SER, Section 22, TMI Item 2.F.2 and SER Supplement 5.

8.

USAR Section 18.2.8.1.

9.

USAR Sections 10.4.9 and 18.2.8.

10.

USAR Section 18.2.13.2.

Enclosure to 001227, Page 14 of 17 Insert:

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

Remote Shutdown System B 3.3.4 Wolf Creek - Unit 1 B 3.3.4-6 Revision 89 BASES SURVEILLANCE SR 3.3.4.2 REQUIREMENTS (continued)

SR 3.3.4.2 verifies each required Remote Shutdown System ASP control circuit and transfer switch performs the intended function. This verification is performed from the auxiliary shutdown panel. Operation of the equipment from the auxiliary shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the unit can be placed and maintained in MODE 3 from the auxiliary shutdown panel and the local stations. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

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

Notes 1 and 2 have been added to exclude the Neutron detectors (Note 1), the reactor trip breakers and RCP breakers (Note 2) from CHANNEL CALIBRATION.

Whenever an RTD is replaced in Function 5 or 6, the next required CHANNEL CALIBRATION of the RTDs is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing elements.

REFERENCES

1.

10 CFR 50, Appendix A, GDC 19.

2.

USAR Table 7.5-2.

Enclosure to 001227, Page 15 of 17 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 3) and TS 5.5.20, Online Monitoring Program.

Insert:

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

RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 Wolf Creek - Unit 1 B 3.4.1-6 Revision 89 BASES SURVEILLANCE SR 3.4.1.3 REQUIREMENTS (continued)

The installed flow instrumentation provides indication as a percentage of total flow rate based on the precision calorimetric heat balance. Plant procedures specify the percentage of the total flow rate required to meet the RCS total flow rate limit. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.1.4 Measurement of RCS total flow rate by performance of a precision calorimetric heat balance allows the installed RCS flow instrumentation to be normalized and verifies the actual RCS flow rate is greater than or equal to the minimum required RCS flow rate. When performing a precision heat balance, the instrumentation used for determining steam pressure, feedwater pressure, feedwater temperature, and feedwater venturi p in the calorimetric calculations shall be calibrated within 7 days prior to performing the heat balance.

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

This SR is modified by a Note that allows entry into MODE 1, without having performed the SR, and placement of the unit in the best condition for performing the SR. The Note states that the SR is not required to be performed until 7 days after 95% RTP. This exception is appropriate since the heat balance requires the plant to be at a minimum of 95% RTP to obtain the stated RCS flow accuracies and the test is only a confirmation of SR 3.4.1.4. The Surveillance shall be performed within 7 days after reaching 95% RTP.

REFERENCES

1.

USAR, Chapter 15.

2.

WCAP-18083-P, Revision 0, Westinghouse Revised Thermal Design Procedure Uncertainty Calculations for the Wolf Creek Generating Station, February 2016.

Enclosure to 001227, Page 16 of 17 Insert:

(excluding transmitters in the Online Monitoring Program)

Insert:

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

LTOP System B 3.4.12 Wolf Creek - Unit 1 B 3.4.12-14 Revision 89 BASES SURVEILLANCE SR 3.4.12.9 REQUIREMENTS (continued)

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 controlled under the Surveillance Frequency Control Program.

REFERENCES

1.

10 CFR 50, Appendix G.

2.

Generic Letter 88-11.

3.

ASME, Boiler and Pressure Vessel Code,Section III.

4.

USAR, Chapter 15.

5.

10 CFR 50, Section 50.46.

6.

10 CFR 50, Appendix K.

7.

Generic Letter 90-06.

8.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

9.

USAR, Section 5.2.2.10.

Enclosure to 001227, Page 17 of 17 Insert:

Alternately, the Frequency for checking the calibration of pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 10) and TS 5.5.20, Online Monitoring Program.

Insert:

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