ML081540220

Issuance of Amendment 218 Regarding Administrative Changes to the Operating License and Technical Specifications

ML081540220
Person / Time
Site:	Robinson
Issue date:	06/19/2008
From:	Vaaler M NRC/NRR/ADRO/DORL/LPLII-2
To:	Walt T Carolina Power & Light Co
Vaaler, Marlayna, NRR/DORL 415-3178
Shared Package
ML081540203	List: ML081540220 ML081540279
References
TAC MD7351
Download: ML081540220 (21)

Text

June 19, 2008 Mr. Thomas D. Walt, Vice President H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550-0790

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 ISSUANCE OF AMENDMENT REGARDING ADMINISTRATIVE CHANGES TO THE OPERATING LICENSE AND TECHNICAL SPECIFICATIONS (TAC NO. MD7351)

Dear Mr. Walt:

The Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 218 to Facility Operating License No. DPR-23 for the H.B. Robinson Steam Electric Plant, Unit No. 2, in response to your application dated November 19, 2007, as supplemented by letter dated February 4, 2008, to make administrative revisions to various Operating License (OL) and Technical Specifications (TS) sections.

Specifically, the amendment changes OL Section 3.G (1) (secondary water chemistry program requirements), OL Section 3.G (2) (leakage reduction program requirements), TS Section 1.1 (Definitions), TS Section 3.1.7 (Rod Position Indication), TS Section 3.4.3 (RCS Pressure and Temperature (P/T) Limits), TS Section 3.4.9 (Pressurizer), TS Section 3.7.4 (Auxiliary Feedwater (AFW) System), TS Section 5.5.12 (Explosive Gas and Storage Tank Radioactivity Monitoring Program), and TS Section 5.6.6 (Post Accident Monitoring (PAM) Instrumentation Report). The changes are administrative in nature and improve the accuracy and clarity of the TSs and OL.

A copy of the related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

Marlayna Vaaler, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosures:

1. Amendment No. 218 to DPR-23

2. Safety Evaluation cc w/encls: See next page

ML081540220 Tech.Specs.:ML081540279 NRR-058 OFFICE LPL2-2/PM LPL2-2/LA ITSB/BC OGC LPL2-2/BC NAME MVaaler RSola RElliott BMizuno TBoyce DATE 06/05/08 06/05/05 06/10/08 06/17/08 06/19/08 Mr. T. D. Walt H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 cc:

Mr. Ernest J. Kapopoulos, Jr. Mr. J. Paul Fulford Plant General Manager Manager, Performance Evaluation and H. B. Robinson Steam Electric Plant, Regulatory Affairs PEB 5 Unit No. 2 Progress Energy Carolinas, Inc.

Progress Energy Carolinas, Inc. Post Office Box 1551 3581 West Entrance Road Raleigh, North Carolina 27602-1551 Hartsville, South Carolina 29550 Mr. David T. Conley Mr. Eric McCartney Associate General Counsel II - Legal Director of Site Operations Department H. B. Robinson Steam Electric Plant, Progress Energy Service Company, LLC Unit No. 2 Post Office Box 1551 Progress Energy Carolinas, Inc. Raleigh, North Carolina 27602-1551 3581 West Entrance Road Hartsville, South Carolina 29550 Public Service Commission State of South Carolina Mr. Curt Castell Post Office Drawer 11649 Supervisor, Licensing/Regulatory Programs Columbia, South Carolina 29211 H. B. Robinson Steam Electric Plant, Unit No. 2 Ms. Beverly Hall, Section Chief Progress Energy Carolinas, Inc. N.C. Department of Environment 3581 West Entrance Road and Natural Resources Hartsville, South Carolina 29550 Division of Radiation Protection 3825 Barrett Dr.

Mr. C. T. Baucom Raleigh, North Carolina 27609-7721 Manager - Support Services - Nuclear H. B. Robinson Steam Electric Plant, Mr. Robert P. Gruber Unit No. 2 Executive Director Progress Energy Carolinas, Inc. Public Staff - NCUC 3581 West Entrance Road 4326 Mail Service Center Hartsville, South Carolina 29550 Raleigh, North Carolina 27699-4326 Mr. Scott D. West Ms. Susan Jenkins Superintendent - Security South Carolina Department of Health H. B. Robinson Steam Electric Plant, Bureau of Land & Waste Management Unit No. 2 2600 Bull Street Progress Energy Carolinas, Inc. Columbia, South Carolina 29201 3581 West Entrance Road Hartsville, South Carolina 29550 Ms. Margaret A. Force Assistant Attorney General U. S. Nuclear Regulatory Commission State of North Carolina Resident Inspectors Office Post Office Box 629 H. B. Robinson Steam Electric Plant Raleigh, North Carolina 27602 2112 Old Camden Road Hartsville, South Carolina 29550 Mr. John H. ONeill, Jr.

Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street NW.

Washington, DC 20037-1128

CAROLINA POWER & LIGHT COMPANY DOCKET NO. 50-261 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 218 Renewed 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 November 19, 2007, as supplemented by letter dated February 4, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, 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 Commissions 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 Commissions 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 Renewed Facility Operating License No. DPR-23 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 218 are hereby incorporated in the license.

The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. DPR-23 and the Technical Specifications Date of Issuance: June 19, 2008

ATTACHMENT TO LICENSE AMENDMENT NO.218 RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace pages 3, 4, and 5 of Renewed Operating License No. DPR-23 with the attached pages 3, 4, and 5.

Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page Insert Page 1.1-5 1.1-5 3.1-15 3.1-15 3.4-7 3.4-7 3.4-8 3.4-8 3.4-21 3.4-21 3.7-11 3.7-11 5.0-18 5.0-18 5.0-27 5.0-27

neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; D. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; E. Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A. Maximum Power Level The licensee is authorized to operate the facility at a steady state reactor core power level not in excess of 2339 megawatts thermal.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 218 are hereby incorporated in the license.

The licensee shall operate the facility in accordance with the Technical Specifications.

(1) For Surveillance Requirements (SRs) that are new in Amendment 176 to Final Operating License DPR-23, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 176. For SRs that existed prior to Amendment 176, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 176.

Renewed Facility Operating License No. DPR-23 Amendment No. 218

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 218 TO RENEWED 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 application dated November 19, 2007 (Agencywide Documents Access Management System (ADAMS) Accession No. ML073320195), as supplemented by letter dated February 4, 2008 (ADAMS Accession No. ML080380327), Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc. (the licensee), requested changes to the Technical Specifications (TSs) for the H. B. Robinson Steam Electric Plant (HBRSEP). The supplemental letter requested an additional administrative TS change that did not expand the scope of the application as originally noticed and did not change the Nuclear Regulatory Commission (NRC or Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on December 31, 2007 (72 FR 74356).

The proposed amendment makes administrative revisions to various Operating License (OL) and TS sections. Specifically, the amendment changes OL Section 3.G (1) (secondary water chemistry program requirements), OL Section 3.G (2) (leakage reduction program requirements), TS Section 1.1 (Definitions), TS Section 3.1.7 (Rod Position Indication),

TS Section 3.4.3 (RCS Pressure and Temperature (P/T) Limits), TS Section 3.4.9 (Pressurizer),

TS Section 3.7.4 (Auxiliary Feedwater (AFW) System), TS Section 5.5.12 (Explosive Gas and Storage Tank Radioactivity Monitoring Program), and TS Section 5.6.6 (Post Accident Monitoring (PAM) Instrumentation Report).

The proposed changes are administrative in nature and improve the quality and accuracy of the TSs and OL as they delete requirements that are obsolete or redundant, or correct and clarify the typing and formatting of other requirements. The proposed revisions will not result in changes to the plant design or the procedural controls for the operation, surveillance, or maintenance of the plant.

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act of 1954, as amended, requires applicants for nuclear power plant operating licenses to include TSs as a part of the license. The TSs ensure the operational capability of structures, systems and components that are required to protect the health and safety of the public. The NRCs regulatory requirements related to the content of the

TSs are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36.

10 CFR 50.36 requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety system settings, and limiting control settings (10 CFR 50.36(d)(1));

(2) limiting conditions for operation (LCOs) (10 CFR 50.36(d)(2)); (3) surveillance requirements (10 CFR 50.36(d)(3)); (4) design features (10 CFR 50.36(d)(4)); and (5) administrative controls (10 CFR 50.36(d)(5)).

Pursuant to 10 CFR 50.90, a licensee may apply for an amendment to its license, including the TSs incorporated into the license. In determining the acceptability of the proposed changes, the NRC staff interprets the requirements of the current version of 10 CFR 50.36. Within this general framework, licensees may revise their current TSs provided that a plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative, or produces clarification (i.e., no requirements are materially altered); (2) the change is more restrictive than the licensees current requirement; or (3) the change is less restrictive than the licensees current requirement, but continues to afford adequate assurance of safety when judged against current regulatory standards.

The staff reviewed the licensees application to determine whether all changes are editorial, administrative, or produce enhanced clarity and accuracy of the HBRSEP TSs without materially altering the plant design, regulatory requirements, or procedural controls for the operation, surveillance, or maintenance of the plant.

3.0 TECHNICAL EVALUATION

3.1 HBRSEP OL Section 3.G (1)

The application stated that the secondary water chemistry program requirements specified in this section are redundant to the requirements of TS 5.5.10, Secondary Water Chemistry Program. Therefore, the licensee proposed to delete this condition from the OL, as it is appropriately addressed elsewhere as a TS program.

The NRC staff confirmed that the requirements contained in OL Section 3.G (1) are adequately and completely included in TS 5.5.10. Therefore, removing this section from the OL does not diminish any requirements currently located in the TSs, and will increase the overall clarity of the OL and TSs. Thus, the proposed change is acceptable as it is administrative in nature.

3.2 HBRSEP OL Section 3.G (2)

The application stated that the leakage reduction program requirements specified in this section are redundant to the requirements of TS 5.5.2, Primary Coolant Sources Outside Containment. Therefore, the licensee proposed to delete this condition from the OL, as it is appropriately addressed elsewhere as a TS program.

The NRC staff confirmed that the requirements contained in OL Section 3.G (2) are adequately and completely included in TS 5.5.2. Therefore, removing this section from the OL does not diminish any requirements currently located in the TSs, and will increase the overall clarity of the OL and TSs. Thus, the proposed change is acceptable as it is administrative in nature.

3.3 HBRSEP TS Section 1.1 The licensee proposed to delete the word the prior to 547°F in the last line of the definition for SHUTDOWN MARGIN in TS 1.1, Definitions. This deletion is a grammar change only and will increase the overall clarity of the TS without altering the meaning of the given definition.

Therefore, the proposed change is acceptable as it is editorial in nature.

3.4 HBRSEP TS Section 3.1.7 The licensee proposed to delete the footnote at the bottom of Page 3.1-15 for TS 3.1.7, Rod Position Indication. The footnote was only applicable during operating Cycle 22; HBRSEP is currently in operating Cycle 25. Therefore, the footnote is obsolete and is being deleted to increase the clarity of the TS. The proposed change is acceptable as it is editorial in nature.

3.5 HBRSEP TS Section 3.4.3 The licensee proposed to make changes to Figure 3.4.3-1 and Figure 3.4.3-2 in TS 3.4.3, RCS Pressure and Temperature (P/T) Limits. When these figures were issued with HBRSEP Amendment No. 202 (ADAMS Accession No. ML050400028), information contained in the proposed figures included with the initial application (ADAMS Accession No. ML042370055) was inadvertently omitted or typed incorrectly.

For Figure 3.4.3-1, in the notes at the top, the Upper Shell Plate Weld ID (W10201-1) was omitted and the words allowance and instrumentation were typed with an uppercase A or I instead of lower case.

In Figure 3.4.3-2, in the notes at the top, the Upper Shell Plate Weld ID (W10201-1) and the Girth Weld ID (10-273) were omitted, the limiting adjusted reference temperature (ART) values for 3/4T of 147 degrees Fahrenheit (°F) and 172 °F were omitted, and the words allowance and instrumentation were typed with an uppercase A or I instead of lower case.

Additionally, in the associated graph, the identifier for the 60 °F/Hr [degrees Fahrenheit per hour] curve is missing the Hr term.

The NRC staff confirmed that the information contained in the originally proposed figures for HBRSEP Amendment No. 202 was inadvertently omitted from the issued TS pages. Therefore, editing the information as outlined above to correct these errors does not diminish any requirements currently located in the TS or change the original intent of HBRSEP Amendment No. 202, and will increase the overall clarity and accuracy of the TS. Accordingly, the proposed change is acceptable as it is editorial in nature.

3.6 HBRSEP TS Section 3.4.9 The licensee proposed to revise LCO Condition B for TS 3.4.9, Pressurizer. For Condition B, the proposed change replaces the less than or equal to symbol () with a less than symbol (<).

The current symbol is incorrect based on LCO requirements that specify a pressurizer heater capacity equal to or greater than 125 kilowatts is acceptable. Therefore, the symbol is in error and is being changed to increase the accuracy of the TS. The proposed change is acceptable as it is editorial in nature and clarifies the LCO requirement.

3.7 HBRSEP TS Section 3.7.4 The licensee proposed to make formatting changes to TS 3.7.4, Auxiliary Feedwater (AFW)

System. Specifically, above the associated table on Page 3.7-11, the words ACTIONS (continued) would be added, and in LCO Condition E, the term OR would be moved to the right to line up properly with the text. These formatting changes are consistent with Standard TS format and will increase the clarity of the TS. Therefore, the proposed change is acceptable as it is solely editorial in nature.

3.8 HBRSEP TS Section 5.5.12 The licensee proposed clarifying revisions to part (a) of TS 5.5.12, Explosive Gas and Storage Tank Radioactivity Monitoring Program. The HBRSEP design is such that the concentration of oxygen in the Waste Gas Decay Tanks is controlled so that it is less than the concentration at which a hydrogen explosion could occur, regardless of the hydrogen concentration.

Because the oxygen concentration is kept below limits, the combination of oxygen and hydrogen in the system will not be able to become an explosive mixture. The current TS wording may imply that there are concentration limits for both hydrogen and oxygen, which is not consistent with the plant design. Therefore, the term hydrogen and is being deleted from part (a) to increase the clarity of the TS. The proposed change is acceptable as it is administrative in nature and does not decrease any requirements currently located in the TS.

3.9 HBRSEP TS Section 5.6.6 The licensee proposed to make changes to TS 5.6.6, Post Accident Monitoring (PAM)

Instrumentation Report. Currently the PAM Instrumentation Report refers to Condition H of TS LCO 3.3.3, Post Accident Monitoring (PAM) Instrumentation. The reference to Condition H should have been changed to Condition G to accompany the renumbering of TS LCO 3.3.3 conditions approved in HBRSEP Amendment No. 216 (ADAMS Accession No. ML071540002).

This revision was inadvertently omitted in the application for the original amendment. Altering the information as outlined above to correct this error does not diminish any requirements currently located in the TS or change the original intent of HBRSEP Amendment No. 216, and will increase the overall accuracy of the TSs. Thus, the proposed change is acceptable as it is administrative in nature.

3.10 Conclusion The NRC staff has concluded that all proposed changes are editorial, administrative, or produce enhanced clarity and accuracy of the HBRSEP TSs without materially altering the plant design, regulatory requirements, or procedural controls for the operation, surveillance, or maintenance of the plant. All proposed revisions are administrative in nature and improve the quality and accuracy of the TSs and OL as they delete requirements that are obsolete or redundant, or correct and clarify the typing and formatting of other requirements. Based on these considerations, the above proposed changes are acceptable in their entirety.

4.0 STATE CONSULTATION

In accordance with the Commission=s regulations, the South Carolina State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. 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 the finding as published in the Federal Register on December 31, 2007 (72 FR 74356). 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.

6.0 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 Commissions 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: Marlayna Vaaler Date: June 19, 2008