(~ DUKE ENERGY¢® Vice President ON01 VP 7800 Rochester Hwy ... Docket Numbers 50-269, 50-270, and 50-287

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  • ( ~ DUKE ENERGY®

    RA-20-0231

    July 23, 2020

    ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

    Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2 and 3

    10 CFR 50.90

    Renewed Facility Operating Licenses Numbers DPR-38, DPR-47, and DPR-55 Docket Numbers 50-269, 50-270, and 50-287

    J. Ed Burchfield, Jr. Vice President

    Oconee Nuclear Station

    Duke Energy ON01 VP I 7800 Rochester Hwy

    Seneca, SC 29672

    o; 864.873.3478 t. 864.873.5791

    Ed.Burchfield@duke-energy.com

    Subject: Supplemental Information for Measurement Uncertainty Recapture Power Uprate License Amendment Request

    References:

    1. Duke Energy letter, License Amendment Request for Measurement Uncertainty Recapture Power Uprate, dated February 19, 2020 (ADAMS Accession No. ML20050D379)

    By letter dated February 19, 2020 (Reference 1 ), Duke Energy Carolinas, LLC (Duke Energy) submitted a License Amendment Request (LAR) for Oconee Nuclear Station (ONS) Units 1, 2 and 3 to support a measurement uncertainty recapture (MUR) power uprate. The proposed amendment to the Technical Specifications (TS) of Renewed Facility Operating License Nos. DPR-38, 47 and 55 would increase each unit's authorized core power level from 2568 megawatts thermal (MWt) to 2610 MWt; an increase of 42 MWt and approximately 1.64% of Rated Thermal Power (RTP).

    The Total Thermal Power Uncertainty Value provided in LAR Enclosure 2, page E2-11 in Table 1.1.E was classified as proprietary in the engineering reports for the bounding uncertainty analyses provided in Attachments 6 and 8 of Enclosure 2. This value has been re-classified as non-proprietary in the subject reports. As such, the revised non-proprietary and proprietary engineering reports are provided in Attachments 1 and 3 of this transmittal. These reports supersede the engineering reports for bounding uncertainty analyses (Cameron documents) provided in Attachments 6 and 8 of Reference 1. The Cameron affidavit, provided in Attachment 2, set forth the basis on which the information may be withheld from public disclosure by the NRG and addresses with specificity the considerations listed in

    Attachment 3 of this letter contains proprietary information. Withhold from Public Disclosure Under 10 CFR 2.390. Upon removal of Attachment 3, this letter is uncontrolled.

  • U. S. Nuclear Regulatory Commission RA-20-0231 Page2

    paragraph (b)(4) of 10 CFR 2.390. Accordingly, it is requested that the information that is proprietary to Cameron be withheld from public disclosure in accordance with 10 CFR 2.390.

    The content of this supplemental correspondence does not change the No Significant Hazards Consideration provided in the original submittal (Reference 1).

    No regulatory commitments are contained in this letter.

    Please refer any questions regarding this submittal to Art Zaremba, Director - Fleet Licensing, at (980) 373-2062.

    I declare under penalty of perjury that the foregoing is true and correct. Executed on July 23, 2020 ..

    Very truly yours,

    } ·£,,/.~ J. Ed Burchfield, Jr. Vice President · Oconee Nuclear Station

    Attachment 1 Non-Proprietary Cameron Reports Attachment 2 Cameron Affidavit Attachment 3 Proprietary Cameron Reports

  • U.S. Nuclear Regulatory Commission RA-20-0231 Page3

    cc w/attachments:

    Ms. Laura A. Dudes, Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257

    Mr. Shawn Williams, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852

    Mr. Jared Nadel NRC Senior Resident Inspector Oconee Nuclear Station

    Ms. Anuradha Nair, Bureau of Environmental Health Services Department of Health & Environmental Control 2600 Bull Street Columbia, SC 29201

  • U.S. Nuclear Regulatory Commission RA-20-0231

    ATTACHMENT 1 NON-PROPRIETARY CAMERON REPORTS (49 pages including cover)

    Caldon® Ultrasonic Engineering Reports

    ER-813NP Rev 7, ER-824NP Rev 7, ER-825NP Rev 7

  • SE:! Sia Rockwe,11 Au1omai,on + Schlurnbe,ger

    Caldon® Ultrasonics

    Engineering Report: ER-813NP Rev 7

    BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT OCONEE UNIT 1 NUCLEAR GENERATING STATION USING THE LEFM~+ SYSTEM

    Prepared by: Joanna Phillips \\ Reviewed by: Ryan Hannas ~ Reviewed for Proprietary Information by: Joanna Phillip~ ~

    July 2020

    ER-813NP Rev. 7 Sensia-Private

    SIH Cross-Out

  • sensia Rockwel l Automation+ Schlumberger

    ER-813NP Rev. 7

    Printed in the United States of America.

    Engineering Report No. ER-813NP Rev 7 June 2020

    Sensia-Private

    SIH Cross-Out

  • sensia Rockwell Automation+ Schlumberger

    Engineering Report: ER-813NP Rev 7

    BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT OCONEE UNIT 1 NUCLEAR GENERATING STATION USING THE LEFMv"'+ SYSTEM

    Table of Contents

    1.0 INTRODUCTION 2.0 SUMMARY 3.0 APPROACH 4.0 OVERVIEW 5.0 REFERENCES

    6.0 APPENDICES

    A Information Supporting Uncertainty in LEFM./+ Flow and Temperature Measurements A.1 LEFM./+ Inputs A.2 LEFM./ + Uncertainty Items/Calculations

    Page 3

    A.3 LEFM./ + Meter Factor Calculation and Accuracy Assessment A.4 [ ] A.5 [ ]

    B Total Thermal Power and Mass Flow Uncertainties using the LEFMv"'+ System

    ER-813NP Rev. 7 Sensia-Private

    Trade Secret & Confidential Commercial Information

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    Rockwell Automation+ Schlumberger

    1.0 INTRODUCTION The LEFM ./ and LEFM ./ +1 are advanced ultrasonic systems that accurately determine the volume flow and temperature of feedwater in nuclear power plants. Using a feed water pressure signal input to the LEFM ./ and LEFM ./ +: mass flow can be determined and, along with the temperature output are used along with plant data to compute reactor core thermal power. The technology underlying the LEFM ./ ultrasonic instruments and the factors affecting their performance are described in a topical report, Reference 1, and a supplement to this topical report, Reference 2. The LEFM./+, which is made of two LEFM./ subsystems, is described in another supplement to the topical report, Reference 3. The exact amount of the uprate allowable under a revision to 1 OCFR50 Appendix K depends not only on the accuracy of the LEFM ./ + instrument, but also on the uncertainties in other inputs to the thermal power calculation.

    It is the purpose of this document to provide an analysis of the uncertainty contribution of the LEFM ./ + System [ ]2 to the overall thermal power uncertainty of Oconee Unit 1 Nuclear Generating Station (Appendix B).

    The uncertainties in mass flow and feed water temperature are also used in the calculation of the overall thermal power uncertainty (Appendix B). [

    ] A detailed discussion of the methodology for combining these terms is described in Reference 3.

    This analysis is a bounding analysis for the Oconee Unit 1 Nuclear Generating Station. [

    ]

    1 The LEFM ./ + is composed of the average flow of two independent LEFM3 subsystems. There are four acoustic paths in an LEFM ./ summing to eight paths in the LEFM ./ +. 2 Maintenance Mode refers to the state when any LEFM ./ + meter has only one of its two LEFM ./ subsystems fully operational, resulting in that meter's computing flow from just the remaining fully operational LEFM ./ subsystem.

    ER-813NP Rev. 7 Sensia-Private

    Trade Secret & Confidential Commercial Information

    Trade Secret & Confidential Commercial Information

    Trade Secret & Confidential Commercial Information

    SIH Cross-Out

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    Rockwell Automation+ Schlumberger

    2.0 SUMMARY For Oconee Unit 1 Nuclear Generating Station, Revision 7 results are as follows:

    1. The mass flow uncertainty approach is documented in Reference 3. The uncertainty in the LEFM./ +'s mass flow of feedwater is as follows:

    o Fully Functional LEFM ./ + system mass flow uncertainty is [ ]

    o Maintenance Mode LEFM ./ + system mass flow uncertainty is [ ].

    2. The uncertainty in the LEFM ./ + feedwater temperature is as follows:

    o Fully Functional LEFM ./ + system temperature uncertainty is [

    o Maintenance Mode LEFM ./ + system the uncertainty is [ ]

    ]

    3. The total thermal power uncertainty approach is documented in Reference 3 and Appendix B of this document. The total uncertainty in the determination of thermal power uses the LEFM ./ + system parameters and plant specific parameters, i.e., heat gain/losses, etc. and is as follows:

    o Thermal power uncertainty using a Fully Functional LEFM ./ + system is ± 0.30%

    o Thermal power uncertainty using a Maintenance Mode LEFM ./ + system is [ ]

    ]

    ER-813NP Rev. 7 Sensia-Private

    Trade Secret & Confidential Commercial Information

    Trade Secret & Confidential Commercial Information

    Trade Secret & Confidential Commercial Information

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  • sensia Page 6

    Rockwell Automation+ Schlumberger

    3.0 APPROACH

    All errors and biases are calc