ML14178B232
| ML14178B232 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/14/2014 |
| From: | Geoffrey Miller Plant Licensing Branch II |
| To: | Capps S Duke Energy Carolinas |
| Miller G | |
| References | |
| TAC MF2983, TAC MF2984 | |
| Download: ML14178B232 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Steven D. Capps Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078-8985 July 14, 2014
SUBJECT:
MCGUIRE NUCLEAR STATION, UNITS 1 AND 2: REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION 3.3.2 SETPOINT (TAC NOS. MF2983 AND MF2984)
Dear Mr. Capps:
By letter dated October 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13262A500), Duke Energy Carolinas, LLC (Duke) submitted a license amendment request, which requested to modify Technical Specification 3.3.2,
. "Engineered Safety Features Actuation System (ESFAS) Instrumentation." Specifically, the proposed change would modify the setpoint for Auxiliary Feedwater Pump Suction Transfer in support of your efforts to comply with NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events."
By letter dated April9, 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 further informational needs. The enclosed document describes the specific information needed.
In a conference call on July 9, 2014, Duke staff indicated that a response to this RAI could be provided within 14 days of the date ofthis letter.
If you have any questions, please call me at 301-415-2481.
Docket Nos. 50-369 and 50-370
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv Sinc:r7. j
(_5Dt)*d /1'<'~
G. Edward Miller, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
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 PumpSuction 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 Apri19, 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:
- 1. Please provide the calculation MCC-1210.04.00.0043 that was generated in support of this LAR.
- 2. In addition to providing the calculation, please clarify the following:
- a. Calculation MCC-1210.04-00-0043 states (see.Calc. Attachment 6, page No.8 of
- 11) on PDF page 61 of 64 that both the "Reference Accuracy (A)" and "Calibration Tolerance (CTE)" is 1.0% of span (0.15 psig) with "press (pressure) switch adjustable range from 1 to 16 psig." On the following page, page 61 of 64
- the "As-Left Tolerance (AL T)" 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 AL T specified in PDF page 61 of 64 is not implemented in the calibration procedure (as described in the paragraph.
quoted below).
ENCLOSURE PDF pages 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 calibration procedure is.+/- 0.3 psig or.+/- 2.67% of calibrated span. Since the methodology of calibrating verifies all attributes of the reference accuracy (Assumption G), the larger value for the calibration tolerance may be substituted for reference accuracy as opposed to inclusion of the calibration tolerance as a separate term (Reference 1),
The calibration tolerance (as-left setting band) is simply the term used to represent reference accuracy and does not represent a separate uncertainty term.
=.+/- 2.67% of calibration span."
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 calibration span will ensure the early detection of instrument channel degradation, compared to reference accuracy band of
.+/- 1% provided by the vendor, and calculated by the licensee.
iv. Please explain how the calculated AL T (see PDF page 62 of 64) is used.
- v. Please explain how the calculated AFT (see PDF page 62 of 64) is used.
- b. PDF page 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 CAIRN 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 calibration span."
PDF page*16 of 64 (Calc. Page No.9) shows that the 2.67% value is used to calculate the term "ep5". PDF page 19 of 64 (Calc. Page No. 12) shows term "eps" u$ed to calculate TLA calculation. Therefore the 2.67% value is used to determine TLA in page 18 of 64 (Calc. ~age 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 actual plant drift study data is not used in selection of the sensor drift band.
- c.
PDF page 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. PDF page 62 of 64 (Calc. Attachment 6, page 9 of 11) states sensor drift (SD) as 2.67% of span.
This drift value is used in TLA calculation in PDF page 15 of 64 (Calc. page 8 of
- 16) for TLA calculation.
- i. 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 larger than 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?
\\
ML141788232 OFFICE N RR/LPL2-1 /PM NRR/LPL2-1 /LA NRR/DE/EICB/BC NAME GEM iller SFigueroa JThorp DATE 07/14/14 06/30/14 07/11/14