ML25056A269

Regulatory Audit Plan in Support of LAR to Use Online Monitoring Methodology

ML25056A269
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	02/26/2025
From:	Michael Mahoney Plant Licensing Branch IV
To:	Gustafson O Entergy Services
Mahoney, M
References
EPID L-2024-LLA-0160
Download: ML25056A269 (8)

Text

February 26, 2025 Otto Gustafson Vice President, Regulatory Assurance Entergy Services, LLC M-ECH-29 1340 Echelon Parkway Jackson, MS 39213

SUBJECT:

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2; GRAND GULF NUCLEAR STATION, UNIT 1; RIVER BEND STATION, UNIT 1; WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REGULATORY AUDIT PLAN IN SUPPORT OF LICENSE AMENDMENT REQUEST TO USE ONLINE MONITORING METHODOLOGY (EPID L-2024-LLA-0160)

Dear Otto Gustafson:

By letter dated December 4, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24339B304), Entergy Operations, Inc. (Entergy, the licensee) submitted a license amendment request to revise the technical specifications (TSs) 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.

The proposed changes would revise the Definitions TS section and add a new Online Monitoring Program to the Administrative Controls TS section. Entergy proposes to use online monitoring (OLM) methodology as the technical bases to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. Entergy stated that the proposed change is based on the U.S. Nuclear Regulatory Commission (NRC)-approved topical report AMS-TR-0720R2-A, Online Methodology Technology to Extend Calibration Intervals for Nuclear Plant Pressure Transmitters (ML21235A493).

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

The NRC staff will conduct the audit virtually via Teams using an electronic portal established by Entergy available to NRC staff from approximately March 31, 2025, through May 31, 2025, with formal audit meetings to be scheduled during this period as needed. The NRC staff reserves the right to extend the audit, if necessary. The detailed audit plan is enclosed with this letter.

If you have any questions, please contact me at 301-415-3867 or by email at Michael.Mahoney@nrc.gov.

Sincerely,

/RA/

Michael Mahoney, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-368, 50-416, 50-458, and 50-382

Enclosure:

Audit Plan cc: Listserv

Enclosure REGULATORY AUDIT PLAN IN SUPPORT OF LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO USE ONLINE MONITORING METHODOLOGY ENTERY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 GRAND GULF NUCLEAR STATION, UNIT 1 RIVER BEND STATION, UNIT 1 WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NOS. 50-313, 50-368, 50-416, 50-458, AND 50-382

1.0 BACKGROUND

By letter dated December 4, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24339B304), Entergy Operations, Inc. (Entergy, the licensee) submitted a license amendment request (LAR) to revise the Technical Specifications (TS) for Arkansas Nuclear One, Units 1 and 2 (ANO, Units 1 and 2); Grand Gulf Nuclear Station, Unit 1 (Grand Gulf); River Bend Station, Unit 1 (River Bend); and Waterford Steam Electric Station, Unit 3 (Waterford 3).

The proposed changes would revise the Definitions TS section and add a new Online Monitoring Program to the Administrative Controls TS section. Entergy proposes to use online monitoring (OLM) methodology as the technical bases to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. Entergy stated that the proposed change is based on the U.S. Nuclear Regulatory Commission (NRC)-approved topical report AMS-TR-0720R2-A, Online Methodology Technology to Extend Calibration Intervals for Nuclear Plant Pressure Transmitters (ML21235A493).

The NRC staffs review of the LAR has commenced in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-101, License Amendment Review Procedures, Revision 6, dated July 31, 2020 (ML19248C539). The NRC staff has determined that a regulatory audit should be conducted in accordance with the NRR Office Instruction LIC-111, Revision 2, Regulatory Audits, dated December 19, 2024 (ML24309A281), for the NRC staff to gain a more detailed understanding of the licensees proposed license amendments.

A regulatory audit is a planned, license-related or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of the licensing or regulatory decision. Performing a regulatory audit of the licensees information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensees processes or

procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, there may be supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.71, Maintenance of records, making of reports, and/or 10 CFR 54.37, Additional records and recordkeeping requirements, which although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensees submitted information.

2.0 REGULATORY AUDIT BASIS An audit was determined to be the most efficient approach toward a timely resolution of questions associated with this LAR review, because the NRC staff will have an opportunity to minimize the potential for further rounds of requests for additional information (RAIs) and ensure no unnecessary burden will be imposed by requiring the licensee to address issues that are no longer necessary to make a safety determination. The NRC staff is requesting an initial set of responses to items in section 5.0 of this audit plan, to be reviewed by the staff using an online reference portal. Upon completion of this audit, the NRC staff is expected to achieve the following.

Confirm licensee information which supports statements made in the LAR.

Determine whether the information included in any examined documents is necessary to be submitted to support a safety conclusion.

The audit information that the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be submitted on the docket.

3.0 REGULATORY AUDIT SCOPE OR METHOD The purpose of the remote audit is to gain a more detailed understanding of licensees proposed LAR. The areas of focus for the regulatory audit are the information contained in the licensees December 4, 2024, submittal, and the proposed audit discussion topics and information requests in section 5.0 of this audit plan.

4.0 AUDIT TEAM The audit will be conducted by NRC staff from NRRs Division of Engineering and External Hazards (DEX), Instrumentation and Controls Branch (EICB) and Division of Safety Systems (DSS), Technical Specifications Branch (STSB). The audit will be led by staff from the NRR Division of Operating Reactor Licensing (DORL). NRC staff from other organizations may be assigned to the team as appropriate and others may participate as observers.

The following are members of the NRC audit team:

TEAM MEMBER TITLE ORGANIZATION Mike Mahoney Michael.Mahoney@nrc.com Project Manager NRR/DORL/LPL4 Gilberto Blas Gilberto.blasrodriguez@nrc.gov Electronics Engineer NRR/DEX/EICB Frederick OBrien Frederick.OBrien@nrc.gov Electronics Engineer NRR/DEX/EICB Tarico Sweat Tarico.Sweat@nrc.gov Reactor Systems Engineer NRR/DSS/STSB 5.0 PROPOSED AUDIT TOPICS AND INFORMATION REQUESTS Audit Topics The provided LAR presents information for the proposed implementation of OLM methodology as presented in topical report, AMS-TR-0720R2-A, for ANO, Units 1 and 2, Grand Gulf, River Bend, and Waterford 3. The purpose is to gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC staffs understanding of the LAR. The NRCs objectives of the audit are the following:

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

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

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

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

Information Requests The NRC staff requests the following documents to be made available for staff review:

1.

ANO2302R0, OLM Amenable Transmitters Report for ANO Unit 1

2.

ANO2307R0, OLM Amenable Transmitters Report for ANO Unit 2

3.

GGN2302R0, OLM Amenable Transmitters Report for Grand Gulf

4.

RBD2302R0, OLM Amenable Transmitters Report for River Bend

5.

WAT2302R0, OLM Amenable Transmitters Report for Waterford

6.

AMS [Analysis and Measurement Services Corporation] Report ANO2303R0, OLM Analysis Methods and Limits Report for ANO Unit 1

7.

AMS Report ANO2308R0, OLM Analysis Methods and Limits for Report ANO Unit 2

8.

AMS Report GGN2303R0, OLM Analysis Methods and Limits Report for Grand Gulf

9.

AMS Report RBD2303R0, OLM Analysis Methods and Limits Report for River Bend

10.

AMS Report WAT2303R0, OLM Analysis Methods and Limits Report for Waterford

11.

AMS Report ANO2304R0, OLM Drift Monitoring Program Report for ANO Unit 1

12.

AMS Report ANO2309R0, OLM Drift Monitoring Program Report for ANO Unit 2

13.

AMS Report GGN2304R0, OLM Drift Monitoring Program Report for Grand Gulf

14.

AMS Report RBD2304R0, OLM Drift Monitoring Program Report for River Bend

15.

AMS Report WAT2304R0, OLM Drift Monitoring Program Report for Waterford

16.

AMS Procedure OLM2201, Procedure for Online Monitoring Data Retrieval

17.

AMS Procedure OLM2202, Procedure for Performing Online Monitoring Data Qualification and Analysis

18.

AMS Report ANO2305R0, OLM Noise Analysis Program Report for ANO Unit 1

19.

AMS Report ANO2310R0, OLM Noise Analysis Program Report for ANO Unit 2

20.

AMS Report GGN2305R0, OLM Noise Analysis Program Report for Grand Gulf

21.

AMS Report RBD2305R0, OLM Noise Analysis Program Report for River Bend

22.

AMS Report WAT2305R0, OLM Noise Analysis Program Report for Waterford

23.

AMS Procedure NPS1501, Procedure for Noise Data Collection from Plant Sensors

24.

AMS Procedure NAR2201, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis 6.0 LOGISTICS The audit will be started once an electronic reference portal is set up and the initial responses to items in section 5.0 are made available to the NRC staff to review. The initial desk audit will be conducted over several weeks. The licensee will be kept informed on a regular basis during periodic discussions with the project manager regarding the progress. The audit may include interactions (e.g., teleconferences or webinars) on a mutually agreeable schedule sufficient to understand or resolve issues associated with the information made available.

7.0 DELIVERABLES An audit summary will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue RAIs to the licensee.

ML25056A269

• concurrence via email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*

NRR/DEX/EICB/BC*

NAME MMahoney PBlechman FSacko DATE 2/24/2025 2/26/2025 02/18/2025 OFFICE NRR/DORL/LPL4/BC*

NRR/DORL/LPL4/PM*

NAME TNakanishi MMahoney DATE 02/26/2025 02/26/2025