ML020150499
| ML020150499 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 01/14/2002 |
| From: | Hansen A NRC/NRR/DLPM/LPD2 |
| To: | Moyer A Carolina Power & Light Co |
| Hansen A, NRR/DLPM, 415-1390 | |
| References | |
| TAC MB3380 | |
| Download: ML020150499 (14) | |
Text
January 14, 2002 Mr. J. W. Moyer, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OF AN AMENDMENT RE: ELIMINATION OF REQUIREMENTS FOR THE POST-ACCIDENT SAMPLING SYSTEM (TAC NO. MB3380)
Dear Mr. Moyer:
The Nuclear Regulatory Commission has issued the enclosed Amendment No. 192 to Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR).
This amendment changes the HBR Technical Specifications (TS) in response to your request dated October 31, 2001.
The amendment deletes TS 5.5.3, Post-Accident Sampling, and thereby eliminates the requirement to have and maintain the Post-Accident Sampling System at HBR. The amendment also deletes Condition 3.G.(4) of the Operating License.
A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's bi-weekly Federal Register notice.
Sincerely,
/RA/
Allen G. Hansen, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosures:
- 1. Amendment No. 192 to DPR-23
- 2. Safety Evaluation cc w/enclosures:
See next page
January 14, 2002 Mr. J. W. Moyer, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OF AN AMENDMENT RE: ELIMINATION OF REQUIREMENTS FOR THE POST-ACCIDENT SAMPLING SYSTEM (TAC NO. MB3380)
Dear Mr. Moyer:
The Nuclear Regulatory Commission has issued the enclosed Amendment No. 192 to Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR).
This amendment changes the HBR Technical Specifications (TS) in response to your request dated October 31, 2001.
The amendment deletes TS 5.5.3, Post-Accident Sampling, and thereby eliminates the requirement to have and maintain the Post-Accident Sampling System at HBR. The amendment also deletes Condition 3.G.(4) of the Operating License.
A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's bi-weekly Federal Register notice.
Sincerely,
/RA/
Allen G. Hansen, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosures:
- 1. Amendment No. 192 to DPR-23
- 2. Safety Evaluation cc w/enclosures: See next page Accession Number: ML020150499 OFFICE PDII-2/PM PDII-2/LA PDII-2/SC NAME AHansen EDunnington RCorreia DATE 12/6/01 11/30/01 12/6/01 OFFICIAL RECORD COPY
AMENDMENT NO. 192 TO FACILITY OPERATING LICENSE NO. DPR H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DISTRIBUTION:
PUBLIC PDII-2 Rdg.
OGC G. Hill (2)
W. Beckner J. Lamb (eMail)
ACRS B. Bonser, RII H. Berkow R. Correia A. Hansen E. Dunnington cc: Robinson Service List
CAROLINA POWER & LIGHT COMPANY DOCKET NO. 50-261 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 192 License No. DPR-23 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Carolina Power & Light Company (the licensee), dated October 31, 2001, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 3.B. of Facility Operating License No. DPR-23 is hereby amended to read as follows:
B. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 192, are hereby incorporated in the license.
Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications.
3.
Also, the license is amended by deleting Paragraph 3.G.(4).
4.
This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Richard P. Correia, Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Attachments:
- 1. Page 4a of License DPR-23
- 2. Changes to the Technical Specifications Date of Issuance: January 14, 2002
ATTACHMENT TO LICENSE AMENDMENT NO. 192 FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Remove Page Insert Page TS page 5.0-8 TS page 5.0-8
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 192 TO FACILITY OPERATING LICENSE NO. DPR-23 CAROLINA POWER & LIGHT COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261
1.0 INTRODUCTION
By letter dated October 31, 2001, the Carolina Power & Light Company (CP&L, the licensee) submitted a request for changes to the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR),
Technical Specifications (TS). The requested changes would delete TS 5.5.3, Post-Accident Sampling, and thereby eliminate the requirement to have and maintain the Post-Accident Sampling System (PASS) at HBR. The amendment also deletes Condition 3.G.(4) of the Operating License.
In the aftermath of the accident at Three Mile Island (TMI), Unit 2, the Nuclear Regulatory Commission (NRC) imposed requirements on licensees for commercial nuclear power plants to install and maintain the capability to obtain and analyze post-accident samples of the reactor coolant and containment atmosphere. The desired capabilities of PASS were described in NUREG-0737, Clarification of TMI Action Plan Requirements. The NRC issued orders to licensees with plants operating at the time of the TMI accident to confirm the installation of PASS capabilities (generally as they had been described in NUREG-0737). A requirement for PASS and related administrative controls was added to the TS of the operating plants and was included in the initial TS for plants licensed during the 1980s and 90s. Additional expectations regarding PASS capabilities were included in Regulatory Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants To Assess Plant and Environs Conditions During and Following an Accident.
Significant improvements have been achieved since the TMI accident in the areas of understanding risks associated with nuclear plant operations and developing better strategies for managing the response to potentially severe accidents at nuclear plants. Recent insights about plant risks and alternate severe accident assessment tools have led the NRC staff to conclude that some TMI Action Plan items can be revised without reducing the ability of licensees to respond to severe accidents. The NRCs efforts to oversee the risks associated with nuclear technology more effectively and to eliminate undue regulatory costs to licensees have prompted the NRC to consider eliminating the requirements for PASS in TS and other parts of the licensing bases of operating reactors.
The NRC staff has completed its review of the topical reports submitted by the Combustion Engineering Owners Group (CEOG) and the Westinghouse Owners Group (WOG) that proposed the elimination of PASS. The justifications for the proposed elimination of PASS requirements center on evaluations of the various radiological and chemical sampling and their potential usefulness in responding to a severe reactor accident or making decisions regarding actions to protect the public from possible releases of radioactive materials. As explained in more detail in the NRC staffs safety evaluations for the two topical reports, the NRC staff has reviewed the available sources of information for use by decisionmakers in developing protective action recommendations and assessing core damage. Based on this review, the NRC staff found that the information provided by PASS is either unnecessary or is effectively provided by other indications of process parameters or measurement of radiation levels. The NRC staff agrees, therefore, with the owners groups that licensees can remove the TS requirements for PASS, revise (as necessary) other elements of the licensing bases, and pursue possible design changes to alter or remove existing PASS equipment.
2.0 BACKGROUND
In a letter dated May 5, 1999 (as supplemented by letter dated April 14, 2000), the CEOG submitted the topical report CE NPSD-1157, Revision 1, Technical Justification for the Elimination of the Post-Accident Sampling System From the Plant Design and Licensing Bases for CEOG Utilities. A similar proposal was submitted on October 26, 1998 (as supplemented by letters dated April 28, 1999, April 10 and May 22, 2000), by the WOG in its topical report WCAP-14986, Post Accident Sampling System Requirements: A Technical Basis. The reports provided evaluations of the information obtained from PASS samples to determine the contribution of the information to plant safety and accident recovery. The reports considered the progression and consequences of core damage accidents and assessed the accident progression with respect to plant abnormal and emergency operating procedures, severe accident management guidance, and emergency plans. The reports provided the owners groups technical justifications for the elimination of the various PASS sampling requirements.
The specific samples and the NRC staffs findings are described in the following evaluation.
The NRC staff prepared this model safety evaluation (SE) relating to the elimination of requirements on post-accident sampling and solicited public comment (65 FR 49271) in accordance with the consolidated line item improvement process (CLIIP). The use of the CLIIP in this matter is intended to help the NRC to efficiently process amendments that propose to remove the PASS requirements from TS. Licensees of nuclear power reactors to which this model apply were informed (65 FR 65018) that they could request amendments confirming the applicability of the SE to their reactors and providing the requested plant-specific verifications and commitments.
3.0 EVALUATION The technical evaluations for the elimination of PASS sampling requirements are provided in the safety evaluations dated May 16, 2000, for the CEOG topical report CE NPSD-1157 and June 14, 2000, for the WOG topical report WCAP-14986. The NRC staffs safety evaluations approving the topical reports are located in the NRCs Agencywide Documents Access and Management System (ADAMS) (Accession Numbers ML003715250 for CE NPSD-1157 and ML003723268 for WCAP-14986).
The ways in which the requirements and recommendations for PASS were incorporated into the licensing bases of commercial nuclear power plants varied as a function of when plants were licensed. Plants that were operating at the time of the TMI accident are likely to have been the subject of confirmatory orders that imposed the PASS functions described in NUREG-0737 as obligations. The issuance of plant-specific amendments to adopt this change, which would remove PASS and related administrative controls from the TS, will supersede the PASS specific requirements imposed by post-TMI confirmatory orders.
As described in its safety evaluations for the topical reports, the NRC staff finds that the following PASS sampling requirements may be eliminated for plants of Combustion Engineering and Westinghouse designs:
- 1. reactor coolant dissolved gases
- 4. reactor coolant pH
- 7. reactor coolant conductivity
- 8. reactor coolant radionuclides
- 9. containment atmosphere hydrogen concentration
- 10. containment oxygen
- 11. containment atmosphere radionuclides
- 12. containment sump pH
- 15. containment sump radionuclides The NRC staff agrees that sampling of radionuclides is not required to support emergency response decisionmaking during the initial phases of an accident because the information provided by PASS is either unnecessary or is effectively provided by other indications of process parameters or measurement of radiation levels. Therefore, it is not necessary to have dedicated equipment to obtain this sample in a prompt manner.
The NRC staff does, however, believe that there could be significant benefits to having information about the radionuclides existing post-accident in order to address public concerns and plan for long-term recovery operations. As stated in the safety evaluations for the topical reports, the NRC staff has found that licensees could satisfy this function by developing contingency plans to describe existing sampling capabilities and what actions (e.g., assembling temporary shielding) may be necessary to obtain and analyze highly radioactive samples from the reactor coolant system (RCS), containment sump, and containment atmosphere. (See item 4.1 under Licensee Verifications and Commitments.) These contingency plans must be available to be used by a licensee during an accident; however, these contingency plans do not have to be carried out in emergency plan drills or exercises. The contingency plans for obtaining samples from the RCS, containment sump, and containment atmosphere may also enable a licensee to derive information on parameters such as hydrogen concentrations in containment and boron concentration and pH of water in the containment sump. The NRC staff considers the sampling of the containment sump to be potentially useful in confirming calculations of pH and boron concentrations and confirming that potentially unaccounted for acid sources have been sufficiently neutralized. The use of the contingency plans for obtaining samples would depend on the plant conditions and the need for information by the decisionmakers responsible for responding to the accident.
In addition, the NRC staff considers radionuclide sampling information to be useful in classifying certain types of events (such as a reactivity excursion or mechanical damage) that could cause fuel damage without having an indication of overheating on core exit thermocouples. However, the NRC staff agrees with the topical reports contentions that other indicators of failed fuel, such as letdown radiation monitors (or normal sampling system), can be correlated to the degree of failed fuel. (See item 4.2 under Licensee Verifications and Commitments.)
In lieu of the information that would have been obtained from PASS, the NRC staff believes that licensees should maintain or develop the capability to monitor radioactive iodines that have been released to offsite environs. Although this capability may not be needed to support the immediate protective action recommendations during an accident, the information would be useful for decisionmakers trying to limit the publics ingestion of radioactive materials. (See item 4.3 under Licensee Verifications and Commitments.)
The NRC staff believes that the changes related to the elimination of PASS that are described in the topical reports, related safety evaluations and this proposed change to TS are unlikely to result in a decrease in the effectiveness of a licensees emergency plan. Each licensee, however, must evaluate possible changes to its emergency plan in accordance with 10 CFR 50.54(q) to determine if the change decreases the effectiveness of its site-specific plan.
Evaluations and reporting of changes to emergency plans should be performed in accordance with applicable regulations and procedures.
The NRC staff notes that redundant, safety-grade, containment hydrogen concentration monitors are required by 10 CFR 50.44(b)(1), are addressed in NUREG-0737 Item II.F.1 and Regulatory Guide 1.97, and are relied upon to meet the data reporting requirements of 10 CFR Part 50, Appendix E, Section VI.2.a.(i)(4). The NRC staff concludes that during the early phases of an accident, the safety-grade hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration. The NRC staff sees value in maintaining the capability to obtain grab samples for complementing the information from the hydrogen monitors in the long term (i.e., by confirming the indications from the monitors and providing hydrogen measurements for concentrations outside the range of the monitors). As previously mentioned, the licensees contingency plan (see item 4.1) for obtaining highly radioactive samples will include sampling of the containment atmosphere and may, if deemed necessary and practical by the appropriate decisionmakers, be used to supplement the safety-related hydrogen monitors.
The elimination of PASS requirements requires the elimination of Condition 3.G.(4) in the operating license. The changes are included in the licensees application to revise the TS in order to take advantage of the CLIIP. The NRC staff has reviewed the changes and agrees that the revisions are necessary due to the removal of the TS section on PASS. The changes do not revise technical requirements beyond that reviewed by the NRC staff in connection with the supporting topical reports or the preparation of the TS improvement incorporated into the CLIIP.
4.0 VERIFICATIONS AND COMMITMENTS As requested by the NRC staff in the notice of availability for this TS improvement, the licensee has addressed the following plant-specific verifications and commitments.
4.1 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and maintain),
contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, containment sump, and containment atmosphere.
The licensee has made a regulatory commitment to develop contingency plans for obtaining and analyzing highly radioactive samples from the RCS, containment sump, and containment atmosphere. The licensee has committed to maintain the contingency plans within its Plant Operating Manual. The licensee will implement this commitment and CP&L will notify the NRC by written correspondence upon implementation of the TS amendment.
4.2 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and maintain), a capability for classifying fuel damage events at the Alert level threshold (typically this is 300 Ci/ml dose equivalent iodine). This capability may utilize the normal sampling system and/or correlations of sampling or letdown line dose rates to coolant concentrations.
The licensee has verified that it has a capability for classifying fuel damage events at the Alert level threshold. The licensee has committed to maintain the capability for the Alert classification within its Emergency Plan Implementing Procedures. The licensee has implemented this commitment.
4.3 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and maintain), the capability to monitor radioactive iodines that have been released to offsite environs.
The licensee has verified that it has the capability to monitor radioactive iodines that have been released to offsite environs. The licensee has committed to maintain the capability for monitoring iodines within its Plant Operating Manual. The licensee has implemented this commitment.
The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensees administrative processes, including its commitment management program.
Should the licensee choose to incorporate a regulatory commitment into the emergency plan, final safety analysis report, or other document with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements.
The NRC staff has determined that the commitments do not warrant the creation of regulatory requirements that would require prior NRC approval of subsequent changes. The NRC staff has agreed that NEI 99-04, Revision 0, Guidelines for Managing NRC Commitment Changes, provides reasonable guidance for the control of regulatory commitments made to the NRC staff.
(See Regulatory Issue Summary 2000-17, Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, dated September 21, 2000.) The commitments should be controlled in accordance with the industry guidance or comparable criteria employed by a specific licensee. The NRC staff may choose to verify the implementation and maintenance of these commitments in a future inspection or audit.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the State of South Carolina official was notified of the proposed issuance of the amendment. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes the Surveillance Requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (66 FR 64286). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: J. Lamb Date: January 14, 2002
Mr. J. W. Moyer H. B. Robinson Steam Electric Carolina Power & Light Company Plant, Unit No. 2 cc:
Mr. William D. Johnson Mr. Mel Fry, Director Vice President and Corporate Secretary N.C. Department of Environment Carolina Power & Light Company and Natural Resources Post Office Box 1551 Division of Radiation Protection Raleigh, North Carolina 27602 3825 Barrett Dr.
Raleigh, North Carolina 27609-7721 Ms. Karen E. Long Assistant Attorney General Mr. Robert P. Gruber State of North Carolina Executive Director Post Office Box 629 Public Staff - NCUC Raleigh, North Carolina 27602 Post Office Box 29520 Raleigh, North Carolina 27626-0520 U.S. Nuclear Regulatory Commission Resident Inspector's Office Mr. Virgil R. Autry, Director H. B. Robinson Steam Electric Plant South Carolina Department of Health 2112 Old Camden Road Bureau of Land & Waste Management Hartsville, South Carolina 29550 Division of Radioactive Waste Management 2600 Bull Street Mr. T. P. Cleary Columbia, South Carolina 29201 Plant General Manager Carolina Power & Light Company Mr. Terry C. Morton H. B. Robinson Steam Electric Plant, Unit No. 2 Manager 3581 West Entrance Road Performance Evaluation and Hartsville, SC 29550 Regulatory Affairs CPB 7 Carolina Power & Light Company Mr. T. D. Walt Post Office Box 1551 Director of Site Operations Raleigh, North Carolina 27602-1551 Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 Mr. John H. ONeill, Jr.
3581 West Entrance Road Shaw, Pittman, Potts & Trowbridge Hartsville, South Carolina 29550 2300 N Street, NW.
Washington, DC 20037-1128 Public Service Commission State of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211 Mr. B. L. Fletcher III Manager - Regulatory Affairs Mr. H. K. Chernoff Carolina Power & Light Company Supervisor, Licensing/Regulatory Programs H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 H. B. Robinson Steam Electric Plant, 3581 West Entrance Road Unit No. 2 Hartsville, South Carolina 29550-0790 3581 West Entrance Road Hartsville, South Carolina 29550