ML12284A130
| ML12284A130 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 09/27/2012 |
| From: | Capps S D Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC ME8213, TAC ME8214 | |
| Download: ML12284A130 (27) | |
Text
Duke Contains sensitive security related information. STEVEN D. CAPPSDuke Vice Presidentt Energy Withhold from public disclosure per 10 CFR 2.390(d)(1) McGuire Nuclear StationDuke EnergyMG01 VP / 12700 Hagers Ferry Rd.Huntersville, NC 28078980-875-4805980-875-4809 faxSteven. Capps@duke-energy. comSeptember 27, 2012 10 CFR 50.90U. S. Nuclear Regulatory CommissionWashington, D.C. 20555ATTENTION: Document Control Desk
Subject:
Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station, Units 1 and 2Docket Nos. 50-369 and 50-370Response to Request for Additional Information Regarding LicenseAmendment Request Related to Measurement Uncertainty RecapturePower Uprate (TAC Nos. ME8213 and ME8214)This letter provides responses to a August 23, 2012 Nuclear Regulatory Commission (NRC)request for additional information (RAI questions 45 and 46) and a September 7, 2012 RAI(questions 47 through 53) related to a March 5, 2012 McGuire Nuclear Station (MNS) Units 1and 2 License Amendment Request (LAR) submitted pursuant to 10 CFR 50.90 in support of ameasurement uncertainty recapture (MUR) power uprate.The responses to questions 50 and 53 in the September 7, 2012 RAI are dependent on theimplementation schedule for each Unit's MUR power uprate, High Pressure Turbinereplacement, and Generator Stator/Exciter replacement. MNS is re-evaluating theimplementation schedule for Unit 1. Therefore, in order to ensure a complete and accurateresponse, MNS requests additional time to respond to questions 50 and 53. MNS anticipatesthat responses to RAI questions 50 and 53 will be provided by October 19, 2012.In addition, this letter provides the following:* A revised response to NRC MUR LAR RAI question 23 originally provided in Enclosure 2of the July 6, 2012 MNS MUR LAR RAI response.* Clarification and changes related to requests for withholding information from publicdisclosure per 10 CFR 2.390 provided in MNS MUR RAI responses dated May 29, 2012and July 16, 2012.Contains sensitive security related information. )DWithhold from public disclosure per 10 CFR 2.390(d)(1)www. duke-energy. corn Nuclear Regulatory CommissionSeptember 27, 2012Page 2NRC MUR LAR RAI questions 45 and 46 provided in the August 23, 2012 RAI and DukeEnergy's responses are provided in Enclosure 1. NRC MUR LAR RAI questions 47 through 49,51, and 52 provided in the September 7, 2012 RAI and Duke Energy's responses are providedin Enclosure 2. The revised response to MUR LAR RAI question 23 is provided in Enclosure 2as part of the response to RAI question 52. Enclosure 3 provides a regulatory commitmentdescribed in this submittal. Enclosure 4 provides tables referenced in the revised response toMUR RAI question 23 and the original response to RAI question 23 provided in correspondencedated July 6, 2012. Enclosure 5 provides revised MNS MUR LAR pages reflecting requiredchanges described in this submittal.Enclosures 6 through 8 provide clarification and changes related to requests for withholdinginformation from public disclosure provided in MNS MUR LAR RAI responses dated May 29,2012 and July 16, 2012. The information in Enclosures 6 through 8 is sensitive security-relatedinformation which Duke Energy requests be withheld from public disclosure per 10 CFR2.390(d)(1). Upon removal of Enclosures 6 through 8, this letter is uncontrolled. As per RIS2005-026 -Control of Sensitive Unclassified Nonsafeguards Information Related To NuclearPower Reactors, an affidavit is not required for sensitive security- related information withheldunder 10 CFR 2.390(d)(1).The conclusions reached in the original determination that this LAR contains No SignificantHazards Considerations and the basis for the categorical exclusion from performing anEnvironmental/Impact Statement have not changed as a result of the RAI responses and otherinformation provided in this submittal.Please contact Kenneth L. Ashe at 980-875-4535 if additional questions arise regarding thisLAR.Sincerely,S. D. CappsEnclosures Nuclear Regulatory CommissionSeptember 27, 2012Page 3cc: w/enclosuresV. M. McCreeRegional Administrator, Region IIU.S. Nuclear Regulatory CommissionMarquis One Tower245 Peachtree Center Ave., NE, Suite 1200Atlanta, GA 30303-1257J. H. Thompson (addressee only)Project Manager (MNS)U.S. Nuclear Regulatory Commission11555 Rockville PikeMail Stop 0-8 G9ARockville, MD, 20852-2738J. ZeilerNRC Senior Resident InspectorMcGuire Nuclear Stationcc: without enclosuresW. L. Cox Ill, Section ChiefNorth Carolina Department of Environment and Natural ResourcesDivision of Environmental HealthRadiation Protection Section1645 Mail Service CenterRaleigh, NC 27699-1645 Nuclear Regulatory CommissionSeptember 27, 2012Page 4OATH AND AFFIRMATIONSteven D. Capps affirms that he is the person who subscribed his name to the foregoingstatement, and that all the matters and facts set forth herein are true and correct to the best ofhis knowledge.Steven D. Capp -Presint, McGuire Nuclear StationSubscribed and sworn to me:&,rJ: f, W ý ý- --'412' IJ)1Datery PublicJAit liZpMy commission expires:vrýDate Nuclear Regulatory CommissionSeptember 27, 2012Page 5bxc w/enclosures:McGuire Master File (MG02DM)NRIAIELL (EC050)S. D. Capps (MG01VP)C. J. Morris III (RNPC32)H. D. Brewer (MG01VP)K. L. Ashe (MG01VP)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 (MG05EE)J. W. Boyle (MG05SE)B.J. Horsley (EC04C)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEEnclosure IMcGuire Nuclear Station'sResponses to MUR LAR RAI Questions 45 and 46 In theAugust 23, 2012 NRC Request for Additional InformationBy letter dated March 5, 2012 (Agencywide Documents Access and Management System(ADAMS), Accession No. ML12082A21 0), Duke Energy Carolinas, LLC (Duke Energy, thelicensee), submitted a license amendment request (LAR) to change the McGuire NuclearStation, Units 1 and 2 (McGuire 1 and 2), Technical Specifications (TSs). The proposed changerevises the TSs to implement a measurement uncertainty recapture (MUR) power uprate forMcGuire 1 and 2.The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensee's submittaland determined that the following additional information is needed in order to complete ourreview:NRC Question 45Please provide the current operating EFPYs for McGuire 1 and 2 to assist in determining themargin available in the current Pressure-Temperature limits for 34 EFPY.McGuire Response to NRC Question 45The operating Effective Full Power Years (EFPYs) for McGuire Nuclear Station (MNS) Units 1and 2 as of September 17, 2012 is as follows:MNS Unit 1: 24.143 EFPYMNS Unit 2: 24.111 EFPYNRC Question 46Please confirm that the ISI records for McGuire 1 and 2 show no Reactor Vessel (RV) surfaceflaws. If any RV surface flaws were detected, please characterize them.Page 1 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEMcGuire Response to NRC Question 46MNS performed a review of MNS Unit 1 and Unit 2 Refueling Outage (RFO) InserviceInspection (ISI) Reports issued since initial startup of the Units. For Unit 1, the reports reviewedencompassed RFOs 1 EOC1 through 1 EOC21. For Unit 2, the reports reviewed encompassedRFOs 2EOC1 through 2EOC20. The purpose of the review was to determine if the inserviceinspections documented in the reports identified any RV surface flaws that were reportable dueto a failure to meet the acceptance criteria of the version of the ASME Section XI Codeapplicable to MNS Unit 1 and Unit 2 at the time of the inservice inspection. MNS confirms thatreview of the Unit 1 RFO ISI Reports did not identify any reportable RV surface flaws. MNSreview of the Unit 2 RFO ISI Reports identified two reportable RV surface flaws documented inthe 1993 2EOC8 RFO ISI Report. The other Unit 2 RFO ISI reports reviewed did not identifyany reportable RV surface flaws.The 2EOC8 RFO ISI Report identified the following RV surface flaws that were reportable dueto a failure to meet the acceptance criteria of the version of the ASME Section Xl Codeapplicable to MNS Unit 2 at the time of the inservice inspection:* An indication was noted in the RV interior consisting of a gouged area in the cladding ofthe lower vessel wall at 290 degrees circumferentially about 2 to 3 inches above thebottom head to bottom head spherical weld and approximately 2 feet up from the incoreinstrumentation nozzle. The length of the indication parallel to the inside surface is3/8 inches and the depth is 3/32 inches. As per a manufacturer's drawing, the minimumdimension for clad thickness is 0.126 inches. Subsequent evaluation in 1993 concludedthat, based upon manufacturer's information and ultrasonic testing (UT)/physicalmeasurement, it did not appear the cladding had been breached and the indication wascharacterized as entirely in the cladding. Conservatively assuming the cladding hadbeen breached and considering the effects of corrosion on the RV base metal, theevaluation concluded that the RV minimum wall thickness requirements would still bemet for the life of the vessel. In addition, the evaluation concluded the indication wouldnot cause the Unit 2 RV to exceed the applicable ASME Code stress intensities andcontinued operation of the RV was acceptable. Based upon the evaluation results,repair of the indication was not warranted. Review of RV interior inspection results inUnit 2 RFO ISI Reports after 1993 did not identify any results which indicated the subjectindication has degraded.* An indication was noted at approximately 129 to 130 degrees on the lower head tobottom head circumferential weld at the surface of the RV outer diameter. The indicationis planar, oriented transverse to the weld, and approximately 0.5 inches deep and2.4 inches in length. Subsequent evaluation in 1993 concluded that the RV couldPage 2 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEcontinue to operate for the life of the plant. Based upon the evaluation results, repair ofthe indication was not warranted. In 1995, based upon new data, the subject indicationwas reclassified from an unacceptable surface connected planar flaw to an acceptablesubsurface volumetric flaw. Inspection of the weld containing the flaw was performed inUnit 2 RFO 2EOC16 (Spring 2005) and the results were acceptable.No changes to the Reactor Coolant System design or operating pressure were made as a partof the power uprate. The operating temperature changes are small and within design limits.The effect of changes in operating conditions due to MUR power uprate have been evaluatedfor the above two indications. It has been determined that MUR power uprate causes noadverse impact to the structural evaluations performed for these indications. Therefore, basedon these evaluations, the Unit 2 RV can operate at MUR conditions for the life of the plantwithout repair to the indications.Page 3 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEEnclosure 2McGuire Nuclear Station'sResponses to MUR LAR Request for Additional Information (RAI) Questions47 Through 49 and 51 Through 52 In the September 7, 2012 NRC RAIBy letter dated March 5, 2012 (Agencywide Documents Access and Management System(ADAMS), Accession No. ML1 2082A21 0), as supplemented, Duke Energy Carolinas, LLC(Duke Energy, the licensee), submitted a license amendment request (LAR) to change theMcGuire Nuclear Station, Units 1 and 2 (McGuire 1 and 2), Technical Specifications (TSs). Theproposed 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 additionalinformation is needed to complete the safety evaluation:NRC Question 47For Prairie Island Nuclear Generating Plant (Prairie Island), the MUR power level is 1677 MWt.With a "Failed" Leading Edge Flow Meter (LEFM), the Prairie Island MUR power uprate allowsoperation at 1677 MWt until the next scheduled daily power calorimetric determination and a7-day allowed outage time (AOT) at the Pre-MUR power level of 1650 MWt. The LAR forMcGuire 1 and 2 is asking for 7-day operation with an out-of-service (OOS) allowance of0.045% (compared to the Pre-MUR power level at Prairie Island) for a 7-day AOT. Providejustifications how the Prairie Island example is applicable for McGuire 1 and 2 MUR LAR.McGuire Response to NRC Question 47As described in the McGuire (MNS) response to MNS MUR LAR RAI Question 49, MNS willimplement a 72-hour AOT for a non-functional LEFM System without application of an OOSallowance of 0.045 percent. This is consistent with previous MUR power uprate applicationsapproved by the NRC. With the agreement to implement a 72-hour AOT, MNS no longerreferences the Prairie Island example as a basis for an extended AOT.Page 1 of 7 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATENRC Question 48Drift evaluations similar to the drift evaluation the licensee performed for the McGuire 1 and 2LEFM AOT have been used by the industry to establish TS surveillance intervals, (e.g. fuelcycle extension from 18-months to 24-months). However, it is not the established industrypractice to rely only on drift evaluation for AOT determination when one or more instrumentchannels are inoperable. Therefore, an evaluation using drift alone is not sufficient to justifyextending an AOT. Please provide additional information to justify the 7-day LEFM AOT.McGuire Response to NRC Question 48As described in the MNS response to MNS MUR LAR RAI Question 49, MNS is not requestingan AOT which would be extended in comparison to an AOT approved by the NRC for previousMUR power uprate applications. Instead, consistent with previous applications, MNS willimplement a 72-hour AOT for a non-functional LEFM System. The basis for the proposed72-hour AOT, which is provided in the below response to RAI Question 49, does not rely solelyon a drift evaluation.NRC Question 49The McGuire 1 and 2 MUR LAR is asking for 7 days plant operation with the above boundingsecondary calorimetric uncertainty (SCU) when the LEFM is inoperable. For previousmeasurement uncertainty recapture (MUR) power uprate applications, the NRC staff approved asimilar AOT with the LEFM inoperable for maximum of 3 days, which is consistent withCameron's analysis and recommendations to operate with a failed LEFM. An AOT of 3 days forrepair or replacement of inoperable instrumentation and controls systems is an establishedpractice in the nuclear power industry. Please explain why a 7-days AOT at the higher powerlevel is needed for McGuire 1 and 2, when the LEFM equipment that justifies operation at thehigher power level is inoperable.McGuire Response to NRC Question 49MNS evaluation of Criterion 1 from ER-1 57P, Rev 8, described in Enclosure 2 of the MUR LARdated March 5, 2012, the MNS response to MUR LAR RAI Question 20c provided incorrespondence dated July 6, 2012, and the MNS response to MUR LAR RAI Question 44provided in correspondence dated August 15, 2012 provided the basis for selection of a 7-dayAOT when an LEFM System is not functional. However, MNS will implement a 72-hour AOT fora non-functional LEFM System consistent with previous MUR power uprate applicationsapproved by the NRC. The basis for the proposed 72-hour AOT, which is consistent with thebasis provided for the 7-day AOT, is as follows:Page 2 of 7 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATE* When an LEFM System is non-functional, signals from an existing ASME flow nozzle willbe used as input to the Secondary Calorimetric portion of the Rated Thermal Power(RTP) calculation in place of the LEFM System. During normal LEFM operations, thesignals from the ASME flow nozzles are calibrated to the LEFM signals and upon LEFMfailure the ASME flow nozzle calibration is locked to the last good LEFM value.* A statistical analysis and review of drift data for plant instrumentation which will providethe ASME flow nozzle signals to the Secondary Calorimetric portion of the RTPcalculation demonstrates instrumentation and RTP drift should be insignificant over a72-hour AOT period. This indicates that, without application of a bias based upon abounding value of RTP SCU, the MNS Units can be operated for 72-hours withoutexceeding the licensed RTP limit when the ASME Flow Nozzle signals are used as aninput to the Secondary Calorimetric portion of the RTP calculation in place of the LEFMSystem.* A review of ASME Flow Nozzle fouling history demonstrates that fouling/de-foulingshould not introduce significant error/drift over a 72-hour AOT period. This indicatesthat, without application of a bias based upon a bounding value of RTP SCU, the MNSUnits can be operated for 72-hours without exceeding the licensed RTP limit when theASME Flow Nozzle signals are used as an input to the Secondary Calorimetric portion ofthe RTP calculation in place of the LEFM System.* It is expected that most issues rendering an LEFM System non-functional could beresolved within a 72-hour AOT.* The NRC has approved a 72-hour AOT for previous MUR power uprate applications.Reference NRC to Shearon Harris correspondence dated May 30, 2012 (AccessionNumber ML1 1356A096), NRC to Calvert Cliffs correspondence dated July 22, 2009(Accession Number ML091820366), and NRC to Limerick correspondence dated April 8,2011 (Accession Number ML1 10691095).Based upon the above and as described in Enclosure 1 and Attachment 1 of Enclosure 2 of theMUR LAR dated March 5, 2012, a Selected Licensee Commitment (SLC) will be added toaddress functional requirements for the LEFMs and appropriate Required Actions andCompletion Times when an LEFM is not functional. If a non-functional LEFM is not restored tofunctional status within 72-hours, then within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> the Unit will be reduced to no more than3411 MWt (the previously licensed rated thermal power). These SLC changes are not providedas part of the MNS MUR LAR or this RAI response but will be controlled using the 10 CFR50.59 process. The above SLC description supersedes the SLC description and related AOTPage 3 of 7 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEtext discussed in the MNS evaluation of Criterion 1 from ER-1 57P, Rev 8, as described inEnclosure 2, Pages E2-6 and E2-7, of the MUR LAR dated March 5, 2012.As part of the MNS evaluation of Criterion 1 from ER-1 57P, Rev 8, described in Enclosure 2 ofthe MUR LAR dated March 5, 2012, the MNS response to MUR LAR RAI Question 20cprovided in correspondence dated July 6, 2012, and the MNS response to MUR LAR RAIQuestions 43 and 44 in correspondence dated August 15, 2012, MNS indicated that, for a 7-dayAOT, additional conservatism would be added by applying a bias based upon the boundingvalue of 0.045% RTP SCU. This bias would be applied to the ASME Flow Nozzle signals usedas an input to the Secondary Calorimetric portion of the RTP calculation when the LEFMSystem is not functional. Also, as described in the response to RAI Question 43 anddocumented in Enclosure 3 of a MNS MUR LAR RAI response letter dated August 15, 2012, fora 7-day AOT, McGuire committed to adding a SLC requirement to perform an analysis on aMNS Unit's LEFM System on an every other outage refueling frequency. This analysis wouldinclude updating the bounding SCU data used to establish the bias based upon the boundingvalue of RTP SCU. As described above, MNS will implement a 72-hour AOT when an LEFMSystem is non-functional. Since the ASME Flow Nozzle fouling/de-fouling related drift,instrumentation related drift, and RTP drift over a 72-hour AOT would be insignificant, it is notnecessary to apply a bias to ensure the licensed RTP remains within the allowed limit while anLEFM System is non-functional. This is consistent with previous MUR power uprateapplications approved by the NRC. Given that MNS will not apply a bias for a 72-hout AOT, thecommitment described in the response to RAI Question 43 and documented in Enclosure 3 ofthe MNS MUR LAR RAI response letter dated August 15, 2012 is withdrawn.A revised Enclosure 2, Pages E2-6 and E2-7, of the MUR LAR dated March 5, 2012 areprovided in Enclosure 5 to reflect changes related to this RAI response.NRC Question 50In 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 notbe changed under post-MUR uprate conditions. Therefore, any changes in switchyard voltagesafter MUR implementation will be dependent on plant loading. Any change in these post-MURswitchyard voltages will be discussed and communicated with the TSO [Transmission SystemOperator] prior to implementation of the MUR.Provide assurance, including the use of a regulatory commitment as appropriate, that anychanges in the switchyard voltages required (so as not to impact the degraded voltage relayPage 4 of 7 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEsettings), corresponding to the post-MUR uprate and HP Turbine replacement conditions, will beevaluated prior to the implementation of MUR uprate.McGuire Response to NRC Question 50As described in the cover letter, the response to this question will be provided in a futuresubmittal.NRC Question 51In the letter by Duke Energy dated July 6, 2012, in response to the NRC staff RAI question 4,the licensee stated that certain reactor vessel level indication reactor temperature detectors(RTDs) were previously determined to be a degraded/non-conforming condition, dependent ontheir installed location. In addition, one of three McGuire 1 pressurizer level transmitters wasdetermined to be inoperable for post-accident monitoring, but operable for other required normaloperation functions. Resolution of these existing conditions, which are being tracked in thecorrective action program, are applicable for current operating conditions and conditions afterMUR implementation.Provide assurance, including the use of a regulatory commitment as appropriate, that the abovementioned RTDs and the pressurizer level transmitter will return to the operable condition priorto the implementation of MUR power uprate.McGuire Response to NRC Question 51This RAI response provides the following regulatory commitment. This commitment isdocumented in Enclosure 3:Unit 2 reactor vessel level indication RTDs (2NCRD8360 and 2NCRD8430) and a Unit 1pressurizer level transmitter (1 NCLT5170), previously identified in the July 6, 2012 MNSresponse to MNS MUR LAR RAI Question 4 as being in a degraded/non-conformingcondition and an inoperable condition respectively, will be returned to an operablecondition prior to implementation of the MUR power uprate on the applicable MNS Unit.Page 5 of 7 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATENRC Question 52In the letter by Duke Energy dated July 6, 2012, the response to RAI question 23 appears to bemissing a table that is needed to complete this response. Please provide this table.McGuire Response to NRC Question 52MNS MUR LAR RAI question 23 was provided as part of an NRC RAI dated June 6, 2012.Duke Energy provided a response to RAI question 23 in Enclosure 2 of a letter dated July 6,2012. The tables referenced in the RAI question 23 response were inadvertently omitted fromthe response submittal. This omission has been entered into the MNS corrective actionprogram for cause evaluation and corrective action. These tables are provided in Enclosure 4.The response to RAI question 23 provided in Enclosure 2 of the letter dated July 6, 2012indicated all changes required to reflect the MUR conditions were being incorporated in theChecworks models and the related databases were undergoing formal validation. As stated inthat response, a preliminary wear rate analysis was performed to assess the impact of the MURon susceptible Flow Accelerated Corrosion (FAC) components and final data, which would beavailable around August 31, 2102, was expected to confirm the preliminary results. A revisedresponse to MNS MUR LAR RAI question 23 is provided below incorporating MUR relatedchanges, final data, and validated results into the MNS FAC program's Checworks models anddatabases. The final data confirms the preliminary results of the wear rate analysis discussed inthe original response to RAI question 23. The below revised response replaces the originalresponse to RAI question 23 provided in Enclosure 2 of the July 6, 2012 MNS MUR LAR RAIresponse submittal.Revised Response to NRC Question 23:As a result of plant and industry experience with pipe degradation in process systems, aFAC program was developed at MNS. The purpose of the program is to monitor pipingsystems that are subject to FAC degradation, and to mitigate pipe wall loss. The FACprogram is based on the guidance of EPRI NSAC-202L-R3, Recommendations for anEffective Flow-Accelerated Corrosion Program.MNS uses the EPRI Checworks Steam/Feedwater Application (SFA) monitoring software tomodel operating conditions, material data, and UT inspection data to provide a calculatedestimate of component wear. The thermodynamic changes associated with the MUR willimpact corrosion rates for components located on FAC susceptible systems. All changesrequired to reflect the MUR conditions have been incorporated in the Checworks modelsand the final results and databases have been validated.Page 6 of 7 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEA wear rate analysis has been performed to assess the impact of the MUR on susceptibleFAC components and sample results are shown in the Tables in Enclosure 4. They providea comparison of the pre-MUR and post-MUR wear rates. Per this analysis, the increase inwear rates due to the MUR power uprate is considered minor and the existing FAC Programis adequate to incorporate the updated predictions.The wear rate analysis results described in the above revised response to RAI question 23 areconsistent with the preliminary results discussed in the original RAI question 23 responseprovided on July 6, 2012. Therefore, the tables in Enclosure 4 are applicable references forboth the tables described in revised response and the original response to RAI question 23.NRC Question 53In 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 supportimplementation during the Unit 2 Fall 2012 refueling outage. Implementation of theapproved amendment on Unit 1 is scheduled to occur during the Spring 2013 refuelingoutage.The NRC staff typically requires that license amendments are implemented within 30 days ofissuance of the amendment. Please provide additional clarification and justification for yourproposed time frame for implementation of the license amendment.McGuire Response to NRC Question 53As described in the cover letter, the response to this question will be provided in a futuresubmittal.Page 7 of 7 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEEnclosure 3List of CommitmentsCommitment I Commitment Date-I-Unit 2 reactor vessel level indication RTDs(2NCRD8360 and 2NCRD8430) and a Unit 1pressurizer level transmitter (1 NCLT5170),previously identified in the July 6, 2012 MNSresponse to MNS MUR LAR RAI Question 4as being in a degraded/non-conformingcondition and an inoperable conditionrespectively, will be returned to an operablecondition prior to implementation of the MURpower uprate on the applicable MNS Unit.Prior to implementation of the MUR poweruprate on the applicable MNS Unit.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEEnclosure 4Tables Referenced In the Revised Response to MUR LAR RAI Question 23 Provided InEnclosure 2 and the Original Response to RAI Question 23 provided on July 6, 2012 MNS Unit I Table Supporting The Response To Question #23Sample of Unit I Components with Highest Increase In Wear Rate Due to MURCHECWORKSTM SFA-Used to Predict Post-MUR Wear Rate' (at 101.7% Power) Which isCompared to Pre-MUR Measured Wear Rate (at 100% Power)Wear Rate(mils/cycle)Pre- Post- Average increaseMUR MUR in wear rate dueCHECWORKS SFA Run Component (100% (101.7% to MURDefinition System Name Power) Power) (mils/cycle) CommentsHeater 1HC037P 2.186 2.312 Remaining susceptible portion of thisHC1 D:HPT to C HTR Bleed 0.204 run definition scheduled for piping1HC031E-T26 4.938 5.22 replacement by 1EOC23HS3D:MSR Drains u/s MSR Drain 1HS0686P 0.826 0.877 0.068CV1 HS0306E 1.39 1.475CFT2/D: B to A HTR Feedwater ICF134P 0.682 0.73 0.0651CF85E 1.169 1.251CFT1/D: FeedPMP to B 1CF46P 0.686 0.734HRFeedwater 0.0621CF129E 1.095 1.171 0.062CMT3D:E to D HTR Condensate 1CM199P 1.393 1.427 0.0461CM182E 2.388 2.446CMT4D: D to C HTR Condensate 1CM215E 1.843 1.901 0.0451CM264P 0.983 1.014HB2D:lst stage MSR Heater 1HB115E 1.012 1.043 0.035reheat Bleed 0.0351HB167P 1.327 1.366HS4D: MSR Drains d/s MSR Drain 1HS0918E 0.557 0.591 0.032CV__ 1HS0330P 0.482 0.5111HW008P 0.321 0.347HW1 D: A to B HTRS Heater 0.025Drain 1 HW094E 0.482 0.505HS1 D-1 st Stage drain MSR Drain 1 HS0771 E 0.403 0.424 0.0181 HS0232P 0.273 0.287HW6D:D to E HTRS Heater 1 HW570E 0.89 0.904 0.012Drain1HW494P 0.602 0.611CMT1D:F HTR to CBP Condensate 1CM080E 0.831 0.84 0.0091CM007P 0.753 0.761HW5D-.C PMP to Heater 1 HW370P 0.399 0.405 0.008Condensate Drain0.81 HW441E 0.739 0.748CMT2D:CBP to E HTR Condensate 1CM158P 0.742 0.749 0.0071CM131E 0.64 0.646Heater 1HW154E 0.826 0.833HW2D:B HTR to C Tank 0.006Drain1HW199P 0.59 0.595 1 1Page 1 of 7 MNS Unit I Table Supporting The Response To Question #23Sample of Unit I Components with Highest Increase In Wear Rate Due to MURCHECWORKSTM SFA-Used to Predict Post-MUR Wear Rate' (at 101.7% Power) Which isCompared to Pre-MUR Measured Wear Rate (at 100% Power)Wear Rate(mils/cycle)Pre- Post- Average increaseMUR MUR in wear rate dueCHECWORKS SFA Run Component (100% (101.7% to MURDefinition System Name Power) Power) (mils/cycle) Comments1CM309P 0.835 0.841 000CM2D: AFTER HW Condensate1CM356E 0.754 0.759HW4D:C TNK to C Heater 1HW334P 0.394 0.403 0.001Pump Drain0.11 HW343E 0.73 0.746HW7D:E to F HTRS Heater 1HW708P 0.643 0.644 0.001Drain1HW605E 0.964 0.9651. Predicted Post-MUR wear rate at the conclusion of Unit 1 Fuel Cycle 23, currentlyscheduled to begin on approximately April 20, 2013 and end on approximatelySeptember 20, 2014.Page 2 of 7 MNS Unit I Table Supporting The Response To Question #23Sample of Unit I Components with Pre-MUR Highest Predicted Wear RatesCHECWORKSTMSFA-Used to Predict Post-MUR Thickness2Which is Compared to Pre-MUR Measured Thickness'......... ~ ~ ~ ~ ~ Rti o,,, P,, : :I .,.~I ~MeasuredK~Pre-MUR ~ Post-MUR ,Thickness 1toMe~asured .~Predicted Post-UThickness I,- Thickness, P rdected i me of Unit n(inhcnes)sice), Thickness i ,t,:'1BBID:BB TANK DRAIN 1BB055E-T18 90 Degree Elbow 4.5 0.237 0.203 0.196 1.04 EOC-16BB1 D:BB TANK DRAIN 1 BB078E-T20 90 Degree Elbow 4.5 0.237 0.209 0.198 1.06 EOC-16CFTI/D-PMP-B HTR 361 1CF3E-T20 45 Degree Elbow 24 1.219 1.161 1.155 1.01 EOC-20CFT1/D-PMP-B HTR 361 1CF21E-T03 45 Degree Elbow 24 1.219 1.144 1.131 1.01 EOC-16CFT2/D-B-A HTR 402F 1CF108E-T52 180 Degree Elbow 22 1.125 1.087 1.073 1.01 EOC-15CFT2/D-B-A HTR 402F 1CF133E-T53 180 Degree Elbow 22 1.125 1.056 1.041 1.01 EOC-14CFT3/D-A HTR-SG 440F 1CF115E-T75 180 Degree Elbow 22 1.125 1.199 1.179 1.02 EOC-17CFT3/D-A HTR-SG 440F 1CF258AT-T78 Tee U/S Main 18 0.938 0.833 0.818 1.02 EOC-17CM2D:AFTER HW W/DATA 1CM319T-T21 Tee D/S Main 36 0.750 0.739 0.729 1.02 EOC-15CM2D:AFTER HW W/DATA 1CM340E-T6 45 Degree Elbow 24 0.688 0.664 0.659 1.01 EOC-19CMT1 D:F HTR t CBP 203 1CM083E-T82 90 Degree Elbow 20 0.375 0.331 0.327 1.01 EOC-20CMT2D:CBP t E HTR 205 1CM143E-T72 90 Degree Elbow 30 0.625 0.623 0.620 1.00 EOC-20CMT3D:E to D htrs 250 1CM187E-T34 180 Degree Elbow 18 0.500 0.462 0.456 1.01 EOC-21CMT3D:E to D htrs 250 1CM184E-T36 90 Degree Elbow 16 0.500 0.450 0.427 1.05 EOC-12CMT4D: D to C htr 288 1CM259E-T30 180 Degree Elbow 16 0.540 0.457 0.439 1.04 EOC-16CMT4D: D to C htr 288 1 CM255E-T31 180 Degree Elbow 16 0.527 0.468 0.450 1.04 EOC-16CMT5D:C HTR to HW 357 1 CM277AE-T39 180 Degree Elbow 16 0.500 0.476 0.456 1.04 EOC-12CMT5D:C HTR to HW 357 1CM298E-T51 90 Degree Elbow 16 0.500 0.464 0.459 1.01 EOC-18HA2D:STM FM RH W/DAT 1 HA335E-T27 90 Degree Elbow 8.625 0.322 0.273 0.266 1.03 EOC-19HA2D:STM FM RH W/DAT 1HA464P-T96 Pipe 8.625 0.322 0.304 0.304 1.00 EOC-19HA3D:BLD-RHTS W/DATA 1HA131P-T86 Pipe 10.75 0.365 0.314 0.305 1.03 EOC-19HA3D:BLD-RHTS W/DATA 1 HA166P-T84 Pipe 8.625 0.322 0.251 0.235 1.07 EOC-17HB1D:HPT-B HTS W/DAT 1HB330E-T11 90 Degree Elbow 14 0.375 0.251 0.141 1.78 EOC-16HB1D:HPT-B HTS W/DAT 1HB337P-T41 Pipe 14 0.375 0.266 0.176 1.51 EOC-11HB2D:STM FM RH W/DAT 1HB167E-T15 90 Degree Elbow 6.625 0.280 0.271 0.237 1.14 EOC-10Page 3 of 7 MNS Unit I Table Supporting The Response To Question #23Sample of Unit I Components with Pre-MUR Highest Predicted Wear RatesCHECWORKSTMSFA-Used to Predict Post-MUR Thickness2Which is Compared to Pre-MUR Measured Thickness'Nominal",'Pipe:Size(inches)Thickniess(inches)Pre-MURiThickness*.Jinches),-Ratio 6f PreMURMeasured ,'Post-MUR ~Thickness toPredicted ! Post-MUR ,,,Thickness Predicted, Tlme of Unit I(inches) I Thickness.' I .ospection3HB2D:STM FM RH W/DAT 1HB314E-T04 90 Degree Elbow 6.625 0.280 0.269 0.229 1.17 EOC-10HC1D:HPT-C HTRS W/DA 1HC035E-T06 90 Degree Elbow 30 0.375 0.328 0.254 1.29 EOC-14HC1D:HPT-C HTRS W/DA 1HC072N-T41A Inlet Nozzle 16 0.500 0.444 0.370 1.2 EOC-16STG DRN w/DAT 1HS0266P-T122 Pipe 6.625 0.280 0.256 0.251 1.02 EOC-18HS1D-1 STG DRN w/DAT 1HS0579E-T049 90 Degree Elbow 5.563 0.258 0.232 0.220 1.05 EOC-17HS2D-2 STG DRN w/DAT 1 HS0372E-T091 90 Degree Elbow 6.625 0.432 0.393 0.387 1.02 EOC-20HS2D-2 STG DRN w/DAT 1 HS0935T-T073 (D/S) .Tee 6.625 0.432 0.376 0.369 1.02 EOC-20HS3D-MSR DRN TO CV 1 HS01 31 E-T056 90 Degree Elbow 8.625 0.322 0.296 0.284 1.04 EOC-17HS3D-MSR DRN TO CV 1 HS0473T-T079 Tee 8.625 0.322 0.280 0.267 1.05 EOC-17HS4D: MSR DRN DIS CV 1HS0163E-T067 90 Degree Elbow 8.625 0.322 0.308 0.303 1.02 EOC-16HS4D: MSR DRN D/S CV 1HS0329E-T063 90 Degree Elbow 8.625 0.322 0.264 0.257 1.03 EOC-14HW1 D:A TO B HTRS 1HW027E-TO60A 90 Degree Elbow 6.625 0.280 0.254 0.246 1.03 EOC-13HW1D:A TO B HTRS 1HW090E-T108 90 Degree Elbow 6.625 0.280 0.254 0.252 1.01 EOC-20HW2D:B HTR TO C TANK 1HW145E-T088D 90 Degree Elbow 8.625 0.322 0.309 0.300 .1.03 EOC-16HW2D:B HTR TO C TANK 1HW212E-T027 90 Degree Elbow 8.625 0.322 0.289 0.285 1.01 EOC-20HW3D:C DRAIN & VENT 1 HW271 E-T054 180 Degree Elbow 10.75 0.365 0.340 0.333 1.02 EOC-20HW3D:C DRAIN & VENT 1HW268E-T056 180 Degree Elbow 10.75 0.365 0.325 0.318 1.02 EOC-20HW4D:C TKS-C PUMPS 1HW335E-T102 90 Degree Elbow 16 0.375 0.390 0.379 1.03 EOC-13HW4D:C TKS-C PUMPS 1 HW351 E-T104 90 Degree Elbow 16 0.375 0.382 0.371 1.03 EOC-13HW5D:C PUMP-CM SYS 1CM372E-T53 90 Degree Elbow 20 0.594 0.596 0.588 1.01 EOC-16HW5D:C PUMP-CM SYS 1HW415T-T045 (D/S) Tee D/S Main 12.75 0.375 0.343 0.337 1.02 EOC-18HW6D:D TO E HTRS 1HW484E-T038A 90 Degree Elbow 6.625 0.280 0.255 0.246 1.04 EOC-16HW6D:D TO E HTRS 1 HW521 E-T037 90 Degree Elbow 6.625 0.280 0.271 0.267 1.01 EOC-20HW7D:E TO F HTRS 1HW624E-T017 90 Degree Elbow 6.625 0.280 0.252 0.247 1.02 EOC-20HW7D:E TO F HTRS 1HW726E-T015 90 Degree Elbow 6.625 0.280 0.259 0.248 1.04 EOC-161. Measured thickness at the time of Unit 1 inspection.2. Predicted Post-MUR thickness at the conclusion of Unit 1 Fuel Cycle 23, currently scheduled to begin onapproximately April 20, 2013 and end on approximately September 20, 2014.3. Inspected after the end of the Unit 1 Fuel Cycle (EOC) indicated.Page 4 of 7 MNS Unit 2 Table Supportinq The Response To Question #23Sample of Unit 2 Components with Highest Increase In Wear Rate Due to MURCHECWORKSTM SFA-Used to Predict Post-MUR Wear Rate1 (at 101.7% Power) Which isCompared to Pre-MUR Measured Wear Rate (at 100% Power)Wear Rate(mils/cycle)Pre- Post- Average increaseMUR MUR in wear rate dueCHECWORKS SFA Run Component (100% (101.7% to MURDefinition System Name Power) Power) (mils/cycle) CommentsThere are only six remaining2HC024E-T04 7.136 7.691 susceptible components in this runHC1 0: HPT to C HTR 0.368 definition and all are currentlyBleed 2HC023E scheduled for replacement by2.328 2.509 2EOC23These components (1st stage MSR2HM076E 1.031 1.328 reheat piping) are scheduled forHeater replacement prior to MUR uprate inBleed refueling outage 2EOC21 (currentscheduled outage start date is2HM045P 0.817 1.053 September 15, 2012).CFT1/D: FeedPmp to B Feedwater 2CF10E-T06 1.419 1.54 0.124HTR2CF103P 1.487 1.614CFT2/D:B to A HTR Feedwater 2CF112E 1.26 1.367 0.1002CF84P 1.09 1.1832HS0417E-HS1 D: 1st stage drain MSR Drain T58A 0.7 0.797 0.0602HS0056P 0.134 0.157HS3D:MSR Drains u/s MSR Drain 2HS0317E 1.662 1.746 0.056CV 2HS0119P 0.562 0.59HW1 D:A to B HTR Heater 2HW066E 0.764 0.801 0.035Drain2HWO18P 0.661 0.6932HW535E-HW6D:D to E HTR Heater T034A 1.087 1.124 0.031Drain2HW494P 0.735 0.759HS4D: MSR Drains d/s MSR Drain 2HS1141E 0.448 0.471 0.022CV 2HS0705P 0.387 0.407HW2D: B HTR to C drain Heater 2HW178E 1.35 1.375 0.021tnk Drain2HW123P 0.912 0.9292HW343E-HW4D:C TNK to C pump Heater T104 0.688 0.71 0.018Drain2HW337P 0.409 0.422HW5D:C PMP to Heater 2HW408E 0.951 0.97 0.017Condensate Drain0.1Condensate Drain 2CM380P 0.674 0.6881. Predicted Post-MUR wear rate at the conclusion of Unit 2 Fuel Cycle 22, currentlyscheduled to begin on approximately October 22, 2012 and end on approximately March8, 2014.Page 5 of 7 MNS Unit 2 Table SuDporting The Response To Question #23Sample of Unit 2 Components with Pre-MUR Highest Predicted Wear RatesCHECWORKSTMSFA-Used to Predict Post-MUR Thickness2Which is Compared to Pre-MUR Measured Thickness',Nominal :~Thickness(inches)BB1 D: BB TK DN W/DAT 2BB072T-T016 Tee U/S Main 4.5 0.237 0.201 0.174 1.16 EOC-8B11 D: BB TK DN W/DAT 2BB073P-T017 Tee DIS Main Ext 4.5 0.237 0.226 0.203 1.11 EOC-8CFTI/D-PMP-B HTR 361 2CF2E-T01 45 Degree Elbow 24 1.219 1.095 1.079 1.01 EOC-16CFTI/D-PMP-B HTR 361 2CF22E-T43 45 Degree Elbow 24 1.219 1.099 1.069 1.03 EOC-1 1CFT3/D-A HTR-SG 440F 2CF301 E-T76 90 Degree Elbow 18 0.938 0.820 0.816 1.00 EOC-20CFT3/D-A HTR-SG 440F 2CF458E-T71 90 Degree Elbow 18 0.938 0.874 0.867 1.01 EOC-19CM2D:AFTER HW W/DAT 2CM319T-T21 Tee U/S Main 36 0.750 0.740 0.725 1.02 EOC-15CM2D:AFTER HW W/DAT 2CM350E-T13 180 Degree Elbow 30 0.625 0.608 0.596 1.02 EOC-16CMT1 D-Fhtr to CBP 210 2CM002E-T81 90 Degree Elbow 16 0.375 0.372 0.363 1.02 EOC-18CMT2D:CBP t E htr 212 2CM113E-T77 Expanding Elbow 20 0.375 0.636 0.609 1.04 EOC-11CMT2D:CBP t E htr 212 2CM124T-T65 (D/S) Tee D/S Main 30 0.625 0.621 0.602 1.03 EOC-11CMT3D:Ehtr t Dhtr 263 2CM184E-T36 45 Degree Elbow 16 0.500 0.490 0.487 1.01 EOC-20CMT4D: D to C htr 296 2CM21 1 E-T57A 90 Degree Elbow 16 0.500 0.482 0.470 1.03 EOC-16CMT4D: D to C htr 296 2CM259E-T30 180 Degree Elbow 18 0.500 0.440 0.421 1.05 EOC-1 5CMT5D:C htr t HW 361 2CM293E-T41 180 Degree Elbow 16 0.500 0.478 0.459 1.04 EOC-14CMT5D:C htr t HW 361 2CM279P-T45 Pipe 16 0.500 0.468 0.461 1.02 EOC-14HAl D: HPToHTR W/DATA 2HA001N-T46A Exit Nozzle 14 0.500 0.424 0.374 1.13 EOC-18HA1 D: HPT-HTR W/DATA 2HAO05N-T45A Exit Nozzle 14 0.500 0.371 0.321 1.16 EOC-18HA2D:SM FM RHT W/DAT 2HA335E-T26 90 Degree Elbow 8.625 0.322 0.230 0.219 1.05 EOC-19HA2D:SM FM RHT W/DAT 2HA334E-T27 90 Degree Elbow 8.625 0.322 0.246 0.235 1.05 EOC-19HA3D: BLD-RHTR W/DAT 2HA033E-T64 45 Degree Elbow 10.750 0.365 0.249 0.239 1.04 EOC-20HA3D: BLD-RHTR W/DAT 2HA068P-T81 Pipe 8.625 0.322 0.295 0.255 1.16 EOC-14HB1 D: HPT-HTR W/DAT 2HB317T-T43 Tee U/S Main 20 0.375 0.258 0.218 1.18 EOC-20HB1 D: HPT-HTR W/DAT 2HB355N-T44A Inlet Nozzle 14 0.500 0.610 0.589 1.04 EOC-20HB2D:SM FM RHT W/DAT 2HB314E-T04 90 Degree Elbow 6.625 0.280 0.197 0.188 1.05 EOC-20Page 6 of 7 MNS Unit 2 Table Supporting The Response To Question #23Sample of Unit 2 Components with Pre-MUR Highest Predicted Wear RatesCHECWORKSTMSFA-Used to Predict Post-MUR Thickness2Which is Compared to Pre-MUR Measured Thickness'HB2D:SM FM RHT WIDAT 2HB313E-T14 90 Degree Elbow 6.625 0.280 0.400 0.350 1.14 EOC-9HC1D: HPT-HTR W/DATA 2HC021T-T30 (BR/SE) Tee Branch 20 0.375 0.302 0.126 2.40 EOC-9HC1 D: HPT-HTR W/DATA 2HC021T-T30 Tee U/S Main 30 0.375 0.275 0.247 1.11 EOC-20HSID:I Stg Drn w/Dat 2HS0070E-T54A 90 Degree Elbow 5.563 0.258 0.238 0.226 1.05 EOC-10HS1D:1 Stg Dm w/Dat 2HS0417E-T58A 90 Degree Elbow 5.563 0.258 0.236 0.228 1.04 EOC-14HS2D:2 Stg Drn w/Dat 2HS0352T-T077 Tee U/S Main 6.625 0.432 0.400 0.374 1.07 EOC-10HS2D:2 Stg Dmn w/Dat 2HS0524E-T075 90 Degree Elbow 6.625 0.432 0.371 0.351 1.06 EOC-12HS3D:MSR Drns US CV 2HS0306E-T081 90 Degree Elbow 8.625 0.322 0.311 0.299 1.04 EOC-17HS3D:MSR Dmns US CV 2HS0689E-T069C 90 Degree Elbow 8.625 0.322 0.289 0.262 1.10 EOC-1 1HS4D: MSR DRNS d/s cv 2HS0502E-T065 90 Degree Elbow 8.625 0.322 0.314 0.311 1.01 EOC-17HS4D: MSR DRNS dis cv 2HS0704E-T068 90 Degree Elbow 8.625 0.322 0.306 0.302 1.01 EOC-1 5HW1D:A-B HTR W/DATA 2HWO16E-T062D 90 Degree Elbow 6.625 0.280 0.239 0.230 1.04 EOC-14HW1D:A-B HTR W/DATA 2HW099E-TO60C 90 Degree Elbow 6.625 0.280 0.252 0.248 1.02 EOC-18HW2D:BHTR-C TK W/DAT 2HW139E-T088A 90 Degree Elbow 8.625 0.322 0.270 0.261 1.03 EOC-17HW2D:BHTR-C TK W/DAT 2HW156E-T025A 90 Degree Elbow 8.625 0.322 0.300 0.284 1.06 EOC-14HW3D:CDRN&VNT W/DAT 2HW276E-T077B 90 Degree Elbow 10.75 0.365 0.354 0.349 1.01 EOC-19HW3D:CDRN&VNT W/DAT 2HW278E-T077A 45 Degree Elbow 10.75 0.365 0.331 0.327 1.01 EOC-19HW4D:C TK-C PM W/DAT 2HW335E-T103 90 Degree Elbow 16 0.375 0.350 0.346 1.01 EOC-18HW4D:C TK-C PM W/DAT 2HW343E-T104 90 Degree Elbow 16 0.375 0.343 0.339 1.01 EOC-18HW5D:C PM-CM W/DATA 2CM372E-T53 90 Degree Elbow 20 0.594 0.640 0.637 1.00 EOC-20HW5D:C PM-CM W/DATA 2HW360E-T87 90 Degree Elbow 12.75 0.375 0.342 0.337 1.01 EOC-18HW6D:D-E HTR W/DATA 2HW485E-T038B 90 Degree Elbow 6.625 0.280 0.258 0.247 1.04 EOC-1 5HW6D:D-E HTR W/DATA 2HW572E-T033A 90 Degree Elbow 6.625 0.280 0.247 0.229 1.08 EOC-1 1HW7D:E-F HTR W/DATA 2HW726E-TO15A 90 Degree Elbow 6.625 0.280 0.248 0.246 1.01 EOC-20HW7D:E-F HTR W/DATA 2HW729E-TO15B 90 Degree Elbow 6.625 0.280 0.255 0.253 1.01 EOC-201. Measured thickness at the time of Unit 2 inspection.2. Predicted Post-MUR thickness at the conclusion of Unit 2 Fuel Cycle 22, currently scheduled to begin onapproximately October 22, 2012 and end on approximately March 8, 2014.3. Inspected after the end of the Unit 2 Fuel Cycle (EOC) indicated.Page 7 of 7 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OFNUCLEAR REGULATION REGARDING A MCGUIRE LICENSE AMENDMENT TO SUPPORTA MEASUREMENT UNCERTAINTY RECAPTURE (MUR) POWER UPRATEEnclosure 5Revisions to Paaes In MNS MUR LAR Dated March 5. 2012 SUMMARY OF RIS 2002-03 REQUESTED INFORMATIONLicense Amendment RequestMarch 5, 2012 Page E2-6Criterion I from ER-157P, Rev 8 -Continued operation at the pre-failure power level for a pre-determined time and the decrease in power that must occur following that time are plant-specific and must be acceptably justified.RESPONSE:Upon loss of an LEFM signal, an existing feedwater ASME Flow Nozzle meter will provide input into theSecondary Calorimetric portion of the Rated Thermal Power (RTP) calculation. An engineeringevaluation was performed to justify an allowed outage time upon loss of the LEFM signal. Thisevaluation is based on calculation of the drift of a Best Estimate of Reactor Power, a weighted averageof the Secondary Calorimetric Power Calculation based upon the feedwater ASME Flow Nozzle metersand the Primary Thermal Power Calculation. The Secondary Calorimetric Power Calculation is used todetermine plant power in the event of a loss of LEFM signal. For purposes of calculating drift of theSecondary Calorimetric parameter, one year of data averaged at 10-minute intervals and reportedevery 15 minutes was evaluated. This allows for potential variability from any seasonal effects.Because the LEFM flow meters are not yet operating, Turbine First Stage pressure was used as thereference against which ASME Flow Nozzle drift was calculated. First Stage pressure was expected tobe stable during the short interval, but any variability of the First Stage pressure indicationconservatively adds to the bounding results of the drift calculation. The above analysis demonstrateddrift of the Secondary Calorimetric portion of the RTP calculation is insignificant and supports a 72-hourout-of-service period for a non-functional LEFM.The Main Feedwater ASME Flow Nozzles readings on which the Secondary Calorimetric is based willbe calibrated to the LEFM output. While functional, the LEFM system corrects and normalizes theASME Flow Nozzle and the Main Feedwater RTD Temperature signals via correction factors to themore accurate LEFM signals. Use of these correction factors account for all of the uncertainty thatexists in the Main Feedwater ASME Flow Nozzle.The above analysis and review of ASME Flow Nozzle fouling and instrumentation calibration historydemonstrates that ASME Flow Nozzle fouling/de-fouling related drift, ASME Flow Nozzleinstrumentation related drift, and RTP drift over a 72-hour period would be insignificant. Thisdemonstrates that MNS Unit 1 and 2 operation at or below RTP would be assured over a 72-hourLEFM out-of-service period. It is expected that most issues rendering an LEFM system non-functionalcould be resolved within a 72-hour out-of-service period.Based upon the above, McGuire will implement a 72-hour Allowed Outage Time (AOT) for a non-functional LEFM system. This is consistent with previous MUR power uprate applications approved bythe NRC. A Selected Licensee Commitment (SLC) will be added to require the LEFM to be restored in72-hours. If the LEFM is not restored within 72-hours, then within six hours the unit will be reduced tono more than 3411 MWt (the previously licensed rated thermal power). SUMMARY OF RIS 2002-03 REQUESTED INFORMATIONLicense Amendment RequestMarch 5, 2012 Page E2-7These requirements ensure that the LEFM inputs are in use whenever power is greater than thepre-uprate RTP level of 3411 MWt and that power will be reduced and maintained at or below thepre-uprate level of 3411 MWt until the LEFM is returned to operable status.Criterion 2 from ER-157P, Rev 8 -A CheckPlus operating with a single failure is not identical toan LEFM Check. Although the effect on hydraulic behavior is expected to be negligible, thismust be acceptably quantified if a licensee wishes to operate using the degraded CheckPlus atan increased uncertainty.RESPONSE:McGuire Nuclear Station will not consider a CheckPlus system with a single failure as a separatecategory; this will be considered as an inoperable LEFM and the same actions identified in response toCriterion 1 from ER-157P, Rev. 8 above will be implemented.Criterion 3 from ER-157P, Rev 8 -An applicant with a comparable geometry can reference theabove Section 3.2.1 finding to support a conclusion that downstream geometry does not have asignificant influence on CheckPlus calibration. However, CheckPlus test results do not apply toa Check and downstream effects with the use of a CheckPlus with disabled components thatmake the CheckPlus comparable to a Check must be addressed. An acceptable method is toconduct applicable Alden Laboratory tests.RESPONSE:As stated in response to Criterion 2 from ER-1 57P, Rev. 8 above, McGuire Nuclear Station will notconsider a CheckPlus system with disabled components as a separate category; this will be consideredas an inoperable LEFM and the same actions identified in response to Criterion 1 above will beimplemented.Criterion 4 from ER-157P, Rev 8 -An applicant that requests a MUR with the upstream flowstraightener configuration discussed in Section 3.2.2 should provide justification for claimedCheckPlus uncertainty that extends the justification provided in Reference 17.(Reference 17 = Letter from Hauser, E (Cameron Measurement Systems), to U.S. NuclearRegulatory Commission, "Documentation to support the review of ER-157P, Revision 8:Engineering Report ER-790, Revision 1, 'An Evaluation of the Impact of 55 Tube Permutit FlowConditioners on the Meter Factor of an LEFM CheckPlus, " March 19, 2010) Since the Reference17 evaluation does not apply to the Check, a comparable evaluation must be accomplished if aCheck is to be installed downstream of a tubular flow straightener.RESPONSE:The ASME feedwater measurement nozzles have a flow straightener immediately upstream. Asdiscussed in Section 1.1.C above, the ASME feedwater measurement nozzles are located much greaterthan 4 L/D from the planned location of the LEFMs. The planned location of the LEFMs is also