MNS-14-056, Response to Request for Additional Information Regarding License Amendment Request (LAR) for Proposed Changes to Technical Specification (TS) 3.3.2, in Support of Compliance with NRC Order EA-12-049 (TAC Nos. MF2741, 2742)

Response to Request for Additional Information Regarding License Amendment Request (LAR) for Proposed Changes to Technical Specification (TS) 3.3.2, in Support of Compliance with NRC Order EA-12-049 (TAC Nos. MF2741, 2742)

ML14205A440
Person / Time
Site:	McGuire, Mcguire
Issue date:	07/22/2014
From:	Capps S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14205A436	List: ML14205A441 MNS-14-056, Response to Request for Additional Information Regarding License Amendment Request (LAR) for Proposed Changes to Technical Specification (TS) 3.3.2, in Support of Compliance with NRC Order EA-12-049 (TAC Nos. MF2741, 2742)
References
EA-12-049, MNS-14-056, TAC MF2741, TAC MF2742
Download: ML14205A440 (8)

Text

Steven D. Capps Vice President DUKE McGuire Nuclear Station ENERGY. MG01VP Duke Energy 112700 Hagers Ferry Road Huntersville, NC 27078 o: 980-875-4805 f: 980-875-4809 Steven.Capps@duke-energy.com July 22, 2014 Serial: MNS-14-056 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Duke Energy Carolinas, LLC (Duke Energy)

McGuire Nuclear Station (MNS), Units 1 and 2 Docket Nos. 50-369 and 50-370 Renewed License Nos. NPF-9 and NPF-17 Response to Request for Additional Information Regarding License Amendment Request (LAR) for Proposed Changes to Technical Specification (TS) 3.3.2, in Support of Compliance with NRC Order EA-1 2-049 (TAC Nos. MF 2741, 2742)

REFERENCES:

1. Letter dated September 12, 2013 from Duke Energy to NRC, License Amendment Request for a revision to Technical Specification 3.3.2 in support of NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events", dated March 12, 2012 (Adams Accession No.) ML13262A500

2. Letter dated April 9, 2014 from NRC to Duke Energy, "Request for Additional Information" Regarding License Amendment Request to Modify Technical Specification 3.3.2 Setpoint. ML14097A118

3. Letter dated April 28, 2014 from NRC to Duke Energy, "Request for Additional Information" Regarding License Amendment Request to Modify Technical Specification 3.3.2 Setpoint. ML14114A526

4. Letter dated May 20, 2014 from Duke Energy to NRC, "Response to Request for Additional Information for Proposed Changes to Technical Specification 3.3.2, in Support of Compliance with NRC Order EA-12-049 (TAC Nos. MF 2741, 2742)

5. Letter dated July 14, 2014 from NRC to Duke Energy, "Request for Additional Information" Regarding License Amendment Request to Modify Technical Specification 3.3.2 Setpoint. ML14178B232

U.S. Nuclear Regulatory Commission July, 22, 2014 Page 2 In Reference 1, Duke Energy submitted a LAR for a revision to TS 3.3.2 in support of NRC Order EA-12-049.

In References 2, 3, and 5 the NRC transmitted Requests for Additional Information (RAIs) regarding the LAR. Reference 4 provided the response to References 2 and 3.

The purpose of this letter is to respond to the Reference 5 RAI letter questions. The enclosures to this letter constitute McGuire's response. In Enclosure 1 the format for each RAI response is to restate the RAI question, followed by the appropriate response. Enclosure 2 is included to provide the requested calculation attachment supporting the information documented in Reference 1 and 5.

There are no regulatory commitments contained in this letter or its attachments.

If you have any questions or require additional information, please contact George Murphy at (980) 875-5715.

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

Executed on July 22, 2014.

Sincerely, Steven D. Capps ENCLOSURES

1. Reference 5 RAI Questions and Responses

2. Attachment 6 of MCC-1210.04-00-0043, Revision 5, Instrument Uncertainty for CA-RN Swapover Suction Pressure Switch Loops

U.S. Nuclear Regulatory Commission July, 22, 2014 Page 3 xc:

V.M. McCree, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 E.J. Leeds, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 0-8C2A 11555 Rockville Pike Rockville, MD 20852-2738 G.E. Miller, Project Manager (MNS and CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station J. Folkwein American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453

ENCLOSURE 1 Reference 5 RAI Questions and Responses

Page 2 of 5 ENCLOSURE 1 REQUEST FOR ADDITIONAL INFORMATION MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATION 3.3.2 AUXILIARY FEEDWATER PUMP SUCTION TRANSFER SETPOINT DOCKET NOS. 50-369 AND 50-370 By letter dated September 12, 2013, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13262A500), Duke Energy Carolinas (Duke) submitted a license amendment request (LAR) to amend the Technical Specifications (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," FUNCTION 6.f, "Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low (c)" for McGuire Nuclear Station, Units 1 and 2, in support of plant modifications required to achieve compliance with the NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements of Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012. By letter dated April 9, 2014 (ADAMS Accession No. ML14097A118), the U.S. Nuclear Regulatory Commission (NRC) staff issued a request for additional information (RAI) to Duke. On May 20, 2014 (ADAMS Accession No. ML14161A231), Duke provided a response to the RAI.

Additionally, and to support the NRC staff review of the LAR, Duke made supporting documentation for this LAR available via an online reference portal. The purpose of the online reference portal was to allow the NRC staff limited access to the supporting documentation to identify those documents, or portions thereof, that need to be docketed to support the NRC staff's evaluation of the LAR. Upon review of the LAR, the May 20, 2014, response, and the online reference portal, the NRC staff has identified the following informational needs:

RAI #1:

Pleaseprovide the calculation MCC-1210.04.00.0043 that was generated in support of this LAR.

RAI #1 Response:

Attachment 2 provides the applicable portion of the Auxiliary Feedwater (AFW) suction pressure switch set-point and uncertainty calculation. Only Attachment 6 and supporting attachments of the calculation were provided, as it represents the future modified plant configuration for the LAR implementation. The calculation utilized the set-point/uncertainty methodology described in Reference 1.

Page 3 of 5 ENCLOSURE 1 RAI #2:

In addition to providing the calculation, please clarify the following:

a. CalculationMCC-1210.04-00-0043 states (see.Calc.Attachment 6, page No.8 of 11) on PDFpage 61 of 64 that both the "Reference Accuracy (A)" and "CalibrationTolerance (C TE)" is 1.0% of span (0.15 psig) with "press(pressure)switch adjustable range from I to 16 psig." On the following page, page 61 of 64, the "As-Left Tolerance (ALT)" is specified as 1.03% span (0.16 psig) for "TSTF-493 AF & AL Tolerances for Technical Specifications Pressure Switches."

i. Please explain why the ALT specified in PDFpage 61 of 64 is not implemented in the calibrationprocedure (as described in the paragraph. quoted below).

PDFpages 14 & 15 of 64 (Calc. page Nos. 7 & 8) of the document state:

"SRA- Sensor Reference Accuracy -Random, Independent term. The vendor states the reference accuracy as +/-1% of the maximum span (Reference J).

However, the'as-left setting band in the calibrationprocedure is +/- 0.3 psig or +/-

2.67% of calibratedspan. Since the methodology of calibratingverifies all attributes of the reference accuracy (Assumption G), the largervalue for the calibrationtolerance may be substituted for reference accuracyas opposed to inclusion of the calibration tolerance as a separate term (Reference 1), The calibrationtolerance (as-left setting band) is simply the term used to represent reference accuracy and does not represent a separate uncertainty term.

= +/- 2.67% of calibrationspan."

ii. How was the ,+2.67% value determined iii. Please provide justifications how the as-left setting band in the calibration procedure of +/- 2.67% of calibrationspan will ensure the early detection of instrument channel degradation,compared to reference accuracyband of +/- 1%

provided by the vendor, and calculatedby the licensee.

iv. Please explain how the calculatedALT (see page 62 of 64) is used.

v. Please explain how the calculatedAFT (see PDFpage 62 of 64) is used.

b. PDFpage 15 of 64 (Calc. Page No. 8) states:

"SD -Sensor Drift-A drift study (Attachment 5) has been performed on the safety related pressure switches in the CA/RN suction pressure function at McGuire... This was performed to show that the drift values provided by the vendor is acceptable to the McGuire actual in-use experience. A 95/95 confidence interval was applied and showed that, +2.67%of calibrated span is conservative relative to actual experience....

= + 2.67% of calibrationspan."

Page 4 of 5 ENCLOSURE 1 PDFpage 16 of 64 (Calc. Page No. 9) shows that the 2.67% value is used to calculate the term "ePS". PDFpage 19 of 64 (CaIc. Page No. 12) shows term "eps "Used to calculate TLA calculation. Therefore the 2.67% value is used to determine TLA in page 18 of 64 (Calc. Page No. 12).

i. Please provide details of the analysis performed on plant drift data including the analysis performed on outlier rejection, normality testing, linearity,and 95/95 confidence level.

ii. Please explain why the actualplant drift study data is not used in selection of the sensor drift band.

c. PDFpage 61 of 64 (Calc. Attachment 6, page 8 of 11) states drift (D) as 3.42% of span.

This 3.42% drift value is used in the AFT calculation. PDFpage 62 of 64 (Calc. Attachment 6, page 9 of 11) states sensor drift (SO) as 2.67% of span. This drift value is used in TLA calculation in PDFpage 15 of 64 (Calc. page 8 of 16) for TLA calculation.

Please explain why sensor drift value of 3.42% is used in AFT calculation and a drift value of 2.67% is used in TLA calculation.

ii. The drift value used for in the AFT is largerthan the drift value used in the TLA; therefore the AFT value does not confirm that the drift value used in the TLU calculation is still valid, as it should. Please explain iii. It is assumed that the item referred to as TLA in the body of the calculation is referred to as TLU in Attachment 6. Correct?

Page 5 of 5 ENCLOSURE 1 RAI #2 Response:

The engineering changes to support the proposed LAR include the replacement of existing Emergency Safety Feature Actuation System (ESFAS) AFW pump suction pressure switches with a different model switch. A different model switch with a wider calibration range is required to accommodate the increased switch calibration set-point. References 1) and 4) previously discussed installation of new pressure switches for the AC independent AFW pump automatic suction transfer feature; however, the replacement of the existing ESFAS AFW pump suction pressure switches was not clearly highlighted.

An informal copy of the entire Auxiliary Feedwater (AFW) suction pressure switch set-point and uncertainty calculation was previously provided to the NRC on the Electronic Share Portal.

The calculation body addresses the setpoint/uncertainty determination for the current plant configuration, whereas Attachment 6 of the calculation supports the future LAR plant configuration. The questions posed within RAI #2 resulted due to apparent discrepancies between the body of the calculation and Attachment 6 of the calculation.

Response to each sub-question within RAI #2 is provided below.

Response to RAI #2a) i, ii, iii: Refer to RAI #2 introductory discussion, no further response required.

Response to RAI #2a) iv, v (Regarding how the TSTF-493 ALT and AFT will be applied):

An example calibration procedure was previously provided in response to Reference 2) RAI #2, which depicted a representative calibration procedure example for implementation of TSTF-493 as-found and as-left calibration requirements. As stated in the prior RAI response (Reference 4), similar calibration procedure changes will be implemented for the AFW pump suction pressure switches addressed by Technical Specification Table 3.3.2-1. In addition to the incorporation of the TSTF-493 as-found and as-left tolerance requirements, the procedure changes will further incorporate requirements for formal evaluation (within the Corrective Action Program) of any instrument channel which could not satisfy the required tolerances. The changes to the AFW pump suction pressure switch calibration procedure will be implemented as part of the engineering change process.

Response to RAI #2b) i, ii: Refer to RAI #2 introductory discussion, no further response required.

Response to RAI #2c) i, ii, iii: Refer to RAI #2 introductory discussion, no further response required.