ML12310A384
| ML12310A384 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 11/01/2012 |
| From: | Capps S Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC ME8213, TAC ME8214 | |
| Download: ML12310A384 (19) | |
Text
Duke Duke STEVEN D.CAPPS Vice President
[DVEnergy. McGuire Nuclear Station Duke Energy MG01 VP / 12700 Hagers Ferry Rd.
Huntersville, NC 28078 980-875-4805 980-875-4809 fax Steven. Capps@duke-energy.com November 1, 2012 10 CFR 50.90 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Document Control Desk
Subject:
Duke Energy Carolinas, LLC (Duke Energy)
McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Response to Request for Additional Information Regarding License Amendment Request Related to Measurement Uncertainty Recapture Power Uprate (TAC Nos. ME8213 and ME8214)
This letter provides responses to questions 50 and 53 in a September 7, 2012 Nuclear Regulatory Commission (NRC) request for additional information (RAI) related to a March 5, 2012 McGuire Nuclear Station (MNS) Units 1 and 2 License Amendment Request (LAR) submitted pursuant to 10 CFR 50.90 in support of a measurement uncertainty recapture (MUR) power uprate.
In addition, this letter provides the following:
- A revision to the marked up Technical Specification Page 1.1-5 provided in Attachment 2, Page A2-4 of the MNS MUR LAR submitted March 5, 2012.
NRC MUR LAR RAI questions 50 and 53 provided in the September 7, 2012 RAI and Duke Energy's responses are provided in Enclosure 1. MNS Unit I License Conditions proposed in this submittal are provided in Enclosure 2. Enclosure 3 documents a regulatory commitment described in this submittal. Enclosure 4 provides revised MNS MUR LAR pages reflecting changes described in this submittal.
www. duke-energy. com
November 1, 2012 Nuclear Regulatory Commission Page 2 Responses to RAI questions 47, 48, 49, 51, and 52 in the September 7, 2012 MUR LAR RAI were provided to the NRC via correspondence dated September 27, 2012.
The conclusions reached in the original determination that this LAR contains No Significant Hazards Considerations and the basis for the categorical exclusion from performing an Environmental/Impact Statement have not changed as a result of the RAI responses and other information provided in this submittal.
Please contact Kenneth L. Ashe at 980-875-4535 if additional questions arise regarding this LAR.
Sincerely, S. D. Capps Enclosures
November 1, 2012 Nuclear Regulatory Commission Page 3 cc: w/enclosures V. M. McCree Regional Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 J. H. Thompson (addressee only)
Project Manager (MNS)
U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD, 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station W. L. Cox Ill, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645
November 1, 2012 Nuclear Regulatory Commission Page 4 OATH AND AFFIRMATION Steven D. Capps affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.
Steven D. Capps, Vicresident, McGuire Nuclear Station Subscribed and sworn to me: I a*.ol Date N*,ery Public -
My commission expires: k%.
Date
November 1, 2012 Nuclear Regulatory Commission Page 5 bxc w/attachments:
McGuire Master File (MG02DM)
NRINELL (EC050)
S. D. Capps (MG01VP)
C. J. Morris III (MG01VP)
H. D. Brewer (MG01VP)
K. L. Ashe (MG01RC)
K. L. Crane (MG01RC)
J. J. Nolin (MG02MO)
J. W. Bryant (MG01RC)
D. C. Smith (MG0273)
M. R. Wilder (MG0273)
B. D. Meyer (MG02MO)
M. C. Nolan (EC05P)
S. M. Snider (MG01VP)
J. W. Boyle (MG05SE)
B.J. Horsley (EC04C)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE Enclosure I McGuire Nuclear Station's Responses to MUR LAR RAI Questions 50 and 53 In The September 7, 2012 NRC Request for Additional Information By letter dated March 5, 2012 (Agencywide Documents Access and Management System (ADAMS), Accession No. ML12082A210), as supplemented, Duke Energy Carolinas, LLC (Duke Energy, the licensee), submitted a license amendment request (LAR) to change the McGuire Nuclear Station, Units 1 and 2 (McGuire 1 and 2), Technical Specifications (TSs). The proposed change revises the TSs to implement a measurement uncertainty recapture (MUR) power uprate for McGuire 1 and 2.
The NRC staff has reviewed the licensee's response and determined that following additional information is needed to complete the safety evaluation:
NRC Question 50 In the letter by Duke Energy dated July 16, 2012, in response to the NRC staff RAI question 40, the licensee stated that the degraded voltage relay settings at the safety-related buses will not be changed under post-MUR uprate conditions. Therefore, any changes in switchyard voltages after MUR implementation will be dependent on plant loading. Any change in these post-MUR switchyard voltages will be discussed and communicated with the TSO [Transmission System Operator] prior to implementation of the MUR.
Provide assurance, including the use of a regulatory commitment as appropriate, that any changes in the switchyard voltages required (so as not to impact the degraded voltage relay settings), corresponding to the post-MUR uprate and HP Turbine replacement conditions, will be evaluated prior to the implementation of MUR uprate.
McGuire Response to NRC Question 50 At the time of the response to NRC staff RAI question 40 provided by letter dated July 16, 2012, the McGuire Nuclear Station (MNS) Unit 1 High Pressure (HP) Turbine Replacement and the Unit 1 Generator Stator/Exciter Replacement were scheduled to be implemented during the Spring 2013 1 EOC22 Refueling Outage (RFO), currently scheduled to start on approximately March 16, 2013 and end on approximately April 20, 2013. Also, at the time of the response to RAI question 40, Unit 1 MUR implementation was scheduled to occur after the 1EOC22 RFO.
This schedule would have allowed any changes in the switchyard voltages required (so as not Page 1 of 7
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE to impact the degraded voltage relay settings), corresponding to the Unit 1 post-MUR uprate and HP Turbine Replacement conditions to be evaluated prior to the implementation of MUR uprate on Unit 1. However, as part of MUR implementation, it will be necessary to re-scale feedwater and steam flow instrumentation. Rescaling this instrumentation online introduces plant risks that can be avoided if MUR is implemented during a RFO. Given this risk, Unit 1 MUR implementation, which is not dependent on implementation of the HP Turbine and Generator Stator/Exciter Replacements, has been rescheduled to occur during the 1 EOC22 RFO. Installation of the Unit 1 CheckPlus Leading Edge Flow Meter (LEFM) system is currently scheduled for this same RFO. Post-installation acceptance testing of the Unit 1 CheckPlus LEFM system will be completed after startup from the 1 EOC22 RFO. In addition, due to vendor delays, the Unit 1 Generator Stator/Exciter Replacement has been rescheduled to occur during the Fall 2014 1EOC23 RFO, currently scheduled to start on approximately September 20, 2014 and end on approximately October 24, 2014. Despite the rescheduled Unit 1 Generator Stator/Exciter Replacement, after implementation of the Unit 1 MUR uprate and Unit 1 HP Turbine Replacement, it is expected that Unit 1 will have the capability to realize the full megawatts thermal (MWt) power uprate allowed by MUR and, from a reliability perspective, the existing Unit 1 Generator Stator/Exciter will allow Unit 1 to generate the expected additional megawatts electrical (MWe).
Given the above implementation schedule, the Unit 1 plant loading used as input to an evaluation of any changes in the switchyard voltages required (so as not to impact the degraded voltage relay settings), corresponding to the Unit 1 post-MUR uprate and Unit 1 HP Turbine Replacement conditions will not be determined until after implementation of the MUR uprate on Unit 1. This evaluation will be performed under post-MUR uprate and HP Turbine Replacement conditions prior to increasing Unit 1 reactor core full steady state power above the current authorized level of 3411 MWt for the first time after Unit 1 MUR implementation. If, after the Unit 1 MUR uprate and Unit 1 HP Turbine Replacement, Unit 1 does not realize the expected full MWt power uprate allowed by MUR and/or, from a reliability perspective, the existing Unit 1 Generator Stator/Exciter will not allow Unit 1 to generate the expected additional MWe, then an additional evaluation will be performed after replacement of the Unit 1 Generator/Stator Exciter in the 1 EOC23 RFO. If this additional evaluation is necessary, any changes in the MNS switchyard voltages required (so as not to impact the degraded voltage relay settings),
corresponding to the Unit 1 post-Generator Stator/Exciter Replacement conditions will be evaluated prior to raising Unit 1 reactor core full steady state power to the expected full MWt power uprate allowed by MUR and/or generating the additional MWe now achievable due to replacement of the Unit 1 Generator Stator/Exciter.
Consistent with the above, as documented in Enclosure 2, MNS would accept a Unit 1 License Condition addressing the following:
- Any changes in the MNS switchyard voltages required (so as not to impact the degraded voltage relay settings), corresponding to the Unit 1 post-MUR uprate and Page 2 of 7
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE HP Turbine Replacement conditions, will be evaluated prior to increasing Unit 1 reactor core full steady state power above 3411 MWt for the first time following implementation of the MUR uprate on Unit 1.
If, after the Unit 1 MUR uprate and Unit 1 HP Turbine Replacement, Unit 1 does not realize the expected full MWt power uprate allowed by MUR and/or, the existing Unit 1 Generator Stator/Exciter will not allow Unit 1 to generate the expected additional MWe, then an additional evaluation will be performed after replacement of the Unit 1 Generator/Stator Exciter in the 1 EOC23 RFO. If this additional evaluation is necessary, any changes in the MNS switchyard voltages required (so as not to impact the degraded voltage relay settings), corresponding to the Unit 1 post-Generator Stator/Exciter Replacement conditions will be evaluated prior to raising Unit 1 reactor core full steady state power to the expected full MWt power uprate allowed by MUR and/or generating additional MWe now achievable due to replacement of the Unit 1 Generator Stator/Exciter. of the MNS MUR LAR dated March 5, 2012 provides a list of regulatory commitments made as a result of the LAR. Commitment 5 in that list states acceptance testing following installation of the CheckPlus LEFM systems in the McGuire units will confirm that as built parameters are within the bounds of the error analyses. The specified completion date for Commitment 5 is prior to implementation of the MUR power uprate. However, as described above, MUR implementation is currently scheduled to be implemented on Unit 1 during the Spring 2013 1EOC22 RFO. Installation of the Unit 1 CheckPlus LEFM system is currently scheduled for this same RFO. Post-installation acceptance testing of the Unit 1 CheckPlus LEFM system will be completed after startup from the 1 EOC22 RFO, after implementation of the MUR power uprate on Unit 1. Therefore, for Unit 1, in lieu of the commitment documented in Commitment 5 of Attachment 1 of the MNS MUR LAR dated March 5, 2012, MNS would accept a Unit 1 License Condition, as documented in Enclosure 2, addressing the following:
Acceptance testing following installation of the MNS Unit 1 CheckPlus LEFM system will confirm that as built parameters are within the bounds of the error analyses prior to increasing Unit 1 reactor core full steady state power above 3411 MWt for the first time following implementation of the MUR uprate on Unit 1.
Until the above post-installation acceptance testing is complete and confirms the Unit 1 CheckPlus LEFM System as built parameters are within the bounds of the error analyses, Unit 1 plant operations will use ASME flow nozzle signals as input to the Secondary Calorimetric portion of the Rated Thermal Power (RTP) calculation following Unit 1 MUR implementation.
Upon completion of successful post-installation acceptance testing, Unit 1 plant operations will use the Unit 1 CheckPlus LEFM system signals as input to the Secondary Calorimetric portion of the RTP calculation.
Page 3 of 7
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE The MNS Unit 2 HP Turbine Replacement and the MNS Unit 2 Generator Stator/Exciter Replacement are occurring during the Unit 2 Fall 2012 2EOC21 RFO, which started on September 15, 2012 and is currently scheduled to end on approximately November 6, 2012.
Given that NRC is still reviewing the March 5, 2012 MNS MUR LAR, implementing MUR on Unit 2 during the 2EOC21 RFO is not possible. Therefore, MUR implementation, which is not dependent on implementation of the HP Turbine and Generator Stator/Exciter Replacements, is currently scheduled to be implemented on Unit 2 in December 2012, after the 2EOC21 RFO.
MNS will manage the risks associated with online implementation of MUR and re-scaling of feedwater and steam flow instrumentation in accordance with MNS procedures and processes.
Installation of the Unit 2 CheckPlus LEFM system is currently scheduled for the 2EOC21 RFO.
Post-installation acceptance testing of the Unit 2 CheckPlus LEFM system will be completed after startup from the 2EOC21 RFO, prior to implementation of the MUR power uprate on Unit 2.
After MUR implementation, Unit 2 will have the capability to realize the full MWt power uprate and the expected additional MWe. Any changes in the MNS switchyard voltages required (so as not to impact the degraded voltage relay settings), corresponding to the Unit 2 post-MUR uprate, HP Turbine Replacement, and Generator Stator/Exciter Replacement conditions will be evaluated prior to implementation of the MUR uprate on Unit 2.
Consistent with the above, this RAI response provides the following MNS switchyard voltage related regulatory commitments. This commitment is documented in Enclosure 3:
Any changes in the MNS switchyard voltages required (so as not to impact the degraded voltage relay settings), corresponding to the Unit 2 post-MUR uprate, Unit 2 HP Turbine Replacement, and Unit 2 Generator Stator/Exciter Replacement conditions, will be evaluated prior to implementation of the MUR uprate on Unit 2.
Given the above Unit 1 License Condition related to LEFM system acceptance testing, McGuire proposes to revise Commitment 5 in Attachment 1 of the MNS MUR LAR dated March 5, 2012 as described below to remove the applicability to Unit 1. This commitment is documented in the revised MNS MUR LAR Attachment 1 provided in Enclosure 4 of this RAI response. This revised Attachment 1 replaces the version provided in the March 5, 2012 MNS MUR LAR:
Acceptance testing following installation of the MNS Unit 2 CheckPlus LEFM system will confirm that as built parameters are within the bounds of the error analyses. This confirmation will occur prior to implementation of the MUR power uprate on Unit 2.
Until successful post-installation acceptance testing confirms the Unit 2 CheckPlus LEFM System as built parameters are within the bounds of the error analyses and the MUR uprate is implemented on Unit 2, Unit 2 plant operations will use ASME flow nozzle signals as input to the Secondary Calorimetric portion of the RTP calculation. Upon completion of successful post-installation acceptance testing of the Unit 2 CheckPlus LEFM system and implementation of the MUR uprate on Unit 2, Unit 2 plant operations will use the Unit 2 CheckPlus LEFM system signals as input to the Secondary Calorimetric portion of the RTP calculation.
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE Note, as part of the July 16, 2012 response to NRC staff RAI question 40, MNS provided minimum 230 KV and 500 KV switchyard voltages agreed upon between MNS and the TSO for N-1 (generator trip) conditions for the pre-MUR and post-MUR operating conditions. The implementation plan described above did not result in any changes to the minimum switchyard voltages provided in the response.
NRC Question 53 In the letter by Duke Energy dated March 5, 2012, it states that:
Duke Energy requests approval of this amendment request by October 5, 2012 to support implementation during the Unit 2 Fall 2012 refueling outage. Implementation of the approved amendment on Unit 1 is scheduled to occur during the Spring 2013 refueling outage.
The NRC staff typically requires that license amendments are implemented within 30 days of issuance of the amendment. Please provide additional clarification and justification for your proposed time frame for implementation of the license amendment.
McGuire Response to NRC Question 53 The current implementation schedule indicates the MNS Unit 1 HP Turbine Replacement will occur during the Spring 2013 1EOC22 RFO, scheduled to start on approximately March 16, 2013 and end on approximately April 20, 2013. Installation of the Unit 1 CheckPlus LEFM system is currently scheduled for this same RFO. Post-installation acceptance testing of the Unit 1 CheckPlus LEFM system will be completed after startup from the 1 EOC22 RFO. Due to vendor delays, the Unit 1 Generator Stator/Exciter Replacement will occur during the Fall 2014 1EOC23 RFO, currently scheduled to start on approximately September 20, 2014 and end on approximately October 24, 2014. MUR implementation, which is not dependent on implementation of the HP Turbine and Generator Stator/Exciter Replacements, is currently scheduled to be implemented on Unit 1 during the 1 EOC22 RFO. As described in the response to RAI question 50, following MUR implementation, Unit 1 will not increase reactor core full steady state power above 3411 MWt until post-installation acceptance testing of the MNS Unit 1 CheckPlus LEFM system confirms that as built parameters are within the bounds of the error analyses. Given the above implementation schedule, as part of NRC approval of the MNS MUR LAR, MNS requests the NRC specify the MNS Unit 1 MUR be implemented within 90 days of the completion of the I EOC22 RFO. This allows for any unforeseen delays in Unit 1 MUR implementation and is consistent with or shorter than implementation times associated with similar amendments issued to Limerick Generating Station, Unit 2 (ML110691095), Calvert Cliffs, Unit 1 (ML091820366), and LaSalle County Station Unit 2 (ML101830361).
Page 5 of 7
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE The current implementation schedule indicates the MNS Unit 2 HP Turbine Replacement, the MNS Unit 2 Generator Stator/Exciter Replacement, and the MNS Unit 2 CheckPlus LEFM System installation will occur during the Unit 2 Fall 2012 2EOC21 RFO, which started on September 15, 2012 and is currently scheduled to end on approximately November 6, 2012.
As per the revised Commitment 5 of Attachment 1 of the MNS MUR LAR dated March 5, 2012 (reference Enclosure 4), post-installation acceptance testing of the Unit 2 CheckPlus LEFM System will occur prior to implementation of the MUR uprate on Unit 2. This testing will be completed following the 2EOC21 RFO. MUR implementation, which is not dependent on implementation of the HP Turbine and Generator Stator/Exciter Replacements, is currently scheduled to be implemented on Unit 2 in December 2012, after the 2EOC21 RFO. Therefore, Duke Energy requests approval of the MNS MUR LAR by December 3, 2012 to support the scheduled MUR implementation on Unit 2. As part of NRC approval of the MNS MUR LAR, MNS requests the NRC specify the MNS Unit 2 MUR be implemented within 90 days of issuance of the Unit 2 amendment. This will ensure sufficient time after issuance of the amendment to accommodate the scheduled implementation date and is consistent with or shorter than implementation times associated with similar amendments issued to Limerick Generating Station, Unit 1 (ML110691095), Shearon Harris, Unit 1 (ML11356A096), Surry Power Station Units 1 and 2 (ML101750002), and North Anna Power Station Units 1 and 2 (ML092250616).
During development of this RAI response, MNS performed a review of the MNS MUR LAR submitted on March 5, 2012 to determine ifthe above implementation plan would require any changes to statements and conclusions in the LAR and RAI responses to date. This review identified the following additional required LAR changes. The revised pages, which replace the corresponding pages in the March 5, 2012 MUR LAR, are provided in Enclosure 4:
" Revise implementation related text in the first paragraph of Enclosure 1, Page E1-3, of the LAR to be consistent with the implementation plan described in this RAI response.
- Revise the marked up Technical Specification (TS) Page 1.1-5 in Attachment 2, Page A2-4 of the LAR and add Page A2-6 of the LAR to ensure the Definition of RTP reflects the appropriate MWt consistent with the MUR implementation schedule. Since MUR uprate will be implemented on a staggered basis for each Unit, the revised marked up TS Page 1.1-5 will have a footnote indicating this change is accomplished by the use of a temporary footnote. This footnote indicates that, following implementation of MUR uprate on the respective Unit, the value of RTP shall be 3469 MWt.
- Revise RTP TS definition related text in Enclosure 1, Page E1-3, of the LAR to indicate, the TS change is accomplished by the use of a temporary footnote. This footnote indicates that, following implementation of MUR uprate on the respective Unit, the value of RTP shall be 3469 MWt.
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE Revise Attachment 1 of the LAR dated March 5, 2012 to add a commitment to ensure submittal of a follow-up administrative license amendment request to delete the superseded footnote on TS Page 1.1-5 described above. This follow-up amendment will be submitted within 180 days after implementation of the MUR uprate on the last Unit.
As part of the review to determine ifthe above implementation plan would require any changes to statements and conclusions in the LAR and RAI responses to date, the impact on the grid related statements and conclusions in the LAR and RAI responses was assessed. System performance was assessed using the same methodology used to provide the basis for the grid related statements and conclusions to date. This assessment was performed considering conditions that will exist during execution of the MUR uprate, HP Turbine Replacements, and Generator Stator/Exciter Replacements consistent with the implementation plan described above, including conditions that would exist if, after the Unit 1 MUR uprate and Unit 1 HP Turbine Replacement in 1 EOC22, Unit 1 cannot achieve the expected full MWt power uprate and/or the expected additional MWe. Based upon that assessment, system performance during all stages of the above implementation plan remains acceptable. Note, it was identified that a clarification is needed regarding the response to MUR LAR RAI question 1.c provided in correspondence dated May 29, 2012. This clarification is provided in the below revised response to RAI question 1 .c which replaces the RAI question 1.c response provided on May 29, 2012. No other required changes in the grid related statements and conclusions in the LAR and RAI responses were identified. The clarification to the RAI question 1.c response does not impact the results of the assessment described above.
NRC Question 1.c Provide the MVARs (mega-voltampere-reactive) required, corresponding to the maximum MW generation expected, based on the agreement with the transmission system operator and meeting the voltage requirement at the switchyard.
Revised McGuire Response to Question 1.c At the point of interconnection, the MVARs required to meet the voltage requirements at the switchyard and corresponding to the maximum acceptable MW generation of approximately 1185 MWe/Unit, is 468 MVAR lagging and (-) 297 MVAR leading. These MVAR values were calculated using a 0.93 power factor (pf) lagging and a 0.97 pf leading requirement as specified in Duke's Facility Connection Requirements. These pf requirements supersede the 0.95 pf lagging and a 0.95 pf leading requirement specified in Duke's Large Generator Interconnection Agreement which was the basis for the March 29, 2012 response to RAI question 1.c. All grid studies and documented generator capabilities support the ability of the new generators to meet the system requirements.
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE Enclosure 2 List of MNS Unit I License Conditions Proposed In This RAI Response Proposed Unit I License Conditions Any changes in the MNS switchyard voltages required (so as not to impact the degraded voltage relay settings), corresponding to the Unit 1 post-MUR uprate and HP Turbine Replacement conditions, will be evaluated prior to increasing Unit 1 reactor core full steady state power above 3411 megawatts thermal for the first time following implementation of the MUR uprate on Unit 1.
If, after the Unit 1 MUR uprate and Unit 1 HP Turbine Replacement, Unit 1 does not realize the expected full MWt power uprate allowed by MUR and/or, the existing Unit 1 Generator Stator/Exciter will not allow Unit 1 to generate the expected additional MWe, then an additional evaluation will be performed after replacement of the Unit 1 Generator/Stator Exciter in the 1 EOC23 RFO. If this additional evaluation is necessary, any changes in the MNS switchyard voltages required (so as not to impact the degraded voltage relay settings),
corresponding to the Unit 1 post-Generator Stator/Exciter Replacement conditions will be evaluated prior to raising Unit 1 reactor core full steady state power to the expected full MWt power uprate allowed by MUR and/or generating additional MWe now achievable due to replacement of the Unit 1 Generator Stator/Exciter.
Acceptance testing following installation of the MNS Unit 1 CheckPlus LEFM system will confirm that as built parameters are within the bounds of the error analyses prior to increasing Unit 1 reactor core full steady state power above 3411 megawatts thermal for the first time following implementation of the MUR uprate on Unit 1.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE Enclosure 3 List of MNS Switchyard Voltage Related Commitments Commitment Commitment Date Any changes in the MNS switchyard voltages Prior to implementation of the MUR uprate on required (so as not to impact the degraded Unit 2.
voltage relay settings), corresponding to the Unit 2 post-MUR uprate, Unit 2 HP Turbine Replacement, and Unit 2 Generator Stator/Exciter Replacement conditions, will be evaluated.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORT A MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE Enclosure 4 Revisions to Pages In MNS MUR LAR Dated March 5, 2012 EVALUATION OF PROPOSED CHANGES License Amendment Request March 5, 2012 Page E1-3 The Unit 2 HP turbine/Main Generator changes are scheduled for the Unit 2 EOC21 outage in Fall 2012. The Unit 1 HP turbine and main generator changes are scheduled for the Unit 1 EOC22 outage (Spring 2013) and the Unit 1 EOC23 outage (Fall 2014) respectively. The turbine/generator changes and LEFM are independent of one another but were designed to work together. Duke Energy is not requesting NRC approval for the turbine/generator changes except for the change to TS Table 3.3.1-1, as noted above. The remainder of the turbine/generator changes will be installed in both units under 10 CFR 50.59.
3 DETAILED DESCRIPTION OF PROPOSED CHANGES To accommodate a rated thermal power level of 3469 megawatts thermal for McGuire Units 1 and 2, Duke Energy proposes to modify the Operating License, Technical Specifications and Technical Specification Bases. The proposed changes are listed below:
TS 1.1, Definition of Rated Thermal Power RATED THERMAL POWER will change from 3411 MWt to 3469 MWt.
Since MUR Uprate will be implemented on a staggered basis for each Unit, this change is accomplished by the use of a temporary footnote which indicates, following implementation of MUR uprate on the respective Unit, the value of RATED THERMAL POWER shall be 3469 MWt.
TS Table 3.7.1-1, OPERABLE Main Steam Safety Valves (MSSVs) versus Maximum Allowable Power Range Neutron Flux High Setpoints in Percent of RATED THERMAL POWER As discussed in Technical Specification (TS) Bases 3.7.1, Actions A.1 and A.2, operation with one or more MSSVs inoperable is permissible if THERMAL POWER is proportionally limited to the relief capacity of the remaining MSSVs. The basis for determining the reduced high flux trip setpoint is detailed in TS Bases 3.7.1, Actions A. 1 and A.2. With the MUR uprate, there is an increase in steam flow as shown in Enclosure 2, Table IV-1. Revised maximum allowable power range neutron flux high setpoints were calculated and resulted in changes to TS Table 3.7.1-1 with 4 and 3 MSSVs per steam generator OPERABLE. The setpoint with 2 MSSVs per steam generator OPERABLE was within the round off error and was not changed. This TS change can be implemented on both units in the common McGuire Units 1 and 2 TS since the limitation on THERMAL POWER is conservative for the unit that has not yet implemented the MUR changes.
Operating Licenses Page 3 - Maximum Power Level For each of the two operating licenses, the steady state licensed power level will change from 3411 MWt to 3469 MWt.
Selected Licensee Commitments (SLCs)
As discussed in Enclosure 2, Criterion 1 from ER-1 57P, Rev. 8, a Selected Licensee Commitment (SLC) is being added to support this LAR. The new SLC adds functionality requirements for the leading edge flow meters and appropriate Required Actions and Completion Times when an LEFM is not functional. The SLC changes are not provided as part of this LAR, but are being controlled using the 10 CFR 50.59 process.
4 TECHNICAL EVALUATION McGuire Units 1 and 2 are presently licensed for a Rated Thermal Power (RTP) of 3411 MWt. A more accurate feedwater flow measurement supports an increase to 3469 MWt. The technical evaluation for this MUR power uprate addressed the following categories: the feedwater flow measurement technique and power measurement uncertainty, accidents and transients that remain bounded at the higher power level, accidents and transients that are not bounded at the higher power level, mechanical/structural/material component integrity and design, electrical equipment design, system design, operating, emergency, and abnormal procedures including associated operator actions, environmental impact, and any changes to the Technical Specifications including protective system setpoints. The evaluation conclusions are summarized in Enclosure 2, in the format of NRC Regulatory Issue Summary (RIS) 2002-03 (Reference 1.2).
Attachment I LICENSEE COMMITMENTS License Amendment Request March 5, 2012 Page Al-I ATTACHMENT I LICENSEE COMMITMENTS The following commitment table identifies those actions committed to by Duke Energy Carolinas, LLC (Duke Energy) in this submittal. Other actions discussed in the submittal represent intended or planned actions by Duke Energy. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments.
Commitment Completion Date 1 Any revisions to setpoint calculations or calibration procedures necessary Prior to implementation of to reflect the increased rated thermal power will be implemented. All the MUR power uprate.
maintenance procedures for the new equipment added for the MUR uprate will be implemented.
2 Duke Energy will complete modifications related to the MUR power uprate Prior to implementation of identified in Enclosure 2, VII.2.B. the MUR power uprate.
3 Duke Energy will revise any impacted operating procedures and complete Prior to implementation of all training of operators on the changes related to the MUR power uprate. the MUR power uprate.
4 Duke Energy will develop maintenance procedures for the Cameron Prior to implementation of equipment, develop a preventive maintenance program, and train the MUR power uprate.
maintenance personnel on those procedures, prior to implementation of the MUR.
5 Acceptance testing following installation of the MNS Unit 2 CheckPlus Prior to implementation of system will confirm that as built parameters are within the bounds of the the MUR power uprate on error analyses. Unit 2.
6 A Selected Licensee Commitment will be added to address functional Prior to implementation of requirements for the LEFMs and appropriate Required Actions and the MUR power uprate.
Completion Times when an LEFM is not functional.
7 An "LEFM System Trouble" alarm window will be added to the control Prior to implementation of room alarm panel to alert the operator when there is a problem with the the MUR power uprate.
LEFM.
8 The procedure related to temporary operation above full steady-state Prior to implementation of licensed power levels will be reviewed and modified as necessary. the MUR power uprate.
9 Duke Energy will re-evaluate the Loss-of-Coolant Accidents (UFSAR Prior to implementation of 15.6.5) consistent with the reload methodology, the MUR power uprate.
10 Duke Energy will submit a follow-up administrative license amendment Within 180 days after request to delete the superseded footnote on Technical Specification Page implementation of the MUR 1.1-5. uprate on the last Unit.
TECHNICAL SPECIFICATION MARKUPS License Amendment Request March 5, 2012 Page A2-4 Definitions 1.1 1.1 Definitions (,continued)
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 3411 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.
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. However, with all RCCAs verified fully inserted by two independent means, it is not necessary to account for a stuck RCCA in the SDM calculation. 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 I and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.
SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing each slave relay and verifying the OPERABILITY of each slave relay. The SLAVE RELAY TEST shall include, as a minimum, a continuity check of associated testable actuation devices.
McGuire Units 1 and 2 1.1-5 Amendment Nos. 255/235 TECHNICAL SPECIFICATION MARKUPS License Amendment Request March 5. 2012 Paae A2-6 Technical Specification Paqe 1.1-5 Insert Insert 1: