RNP-RA/09-0092, Revised No Significant Hazards Consideration Determination for Technical Specifications Change to Section 3.3.1 Reactor Protection System Instrumentation
| ML092990205 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/20/2009 |
| From: | Bernie White Carolina Power & Light Co, Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RNP-RA/09-0092 | |
| Download: ML092990205 (5) | |
Text
10 CFR 50.90 SProgress Energy Serial: RNP-RA/09-0092 OCT 2 0 2009 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 REVISED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION FOR TECHNICAL SPECIFICATIONS CHANGE TO SECTION 3.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION Ladies and Gentlemen:
In accordance with the provisions of the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. (PEC), has submitted a request for an amendment to the Technical Specifications (TS) contained in Appendix A of the Operating License for H. B. Robinson Steam Electric Plant (HBRSEP),
Unit No. 2. The request for license amendment was provided by letter dated June 19, 2009.
The proposed amendment will revise TS 3.3.1, "Reactor Protection System Instrumentation."
The proposed change revises the requirements related to the reactor protection system interlock for the turbine trip input to the reactor protection system.
A revised No Significant Hazards Determination for the proposed license amendment is being provided by this letter. Attachment I provides an Affirmation as required by 10 CFR 50.30(b).
Attachment II provides the revised No Significant Hazards Consideration Determination.
If you have any questions concerning this matter, please Curt Castell at (843) 857-1626.
Sincerely, B. C. White Manager - Support Services - Nuclear Progress Energy Carolinas, Inc.
Robinson Nuclear Plant 3581 West Entrance Road Hartsville, SC 29550 Kingf
United States Nuclear Regulatory Commission Serial: RNP-RA/09-0092 Page 2 of 2 Attachments:
I.
Affirmation II.
Revised No Significant Hazards Consideration Determination BCW/cac c:
Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)
Mr. A. Gantt, Chief, Bureau of Radiological Health (SC)
Mr. L. A. Reyes, NRC, Region II Mr. T. Orf, NRC Project Manager, NRR NRC Resident Inspector, HBRSEP Attorney General (SC)
United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/09-0092 Page 1 of 1 AFFIRMATION The information contained in letter RNP-RA/09-0092 is true and correct to the best of my information, knowledge, and belief; and the sources of my information are officers, employees, contractors, and agents of Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. I declare under penalty of perjury that the foregoing is true and correct.
Executed On:
OCT 2 0 2009 E.
B.
MctNan Vice President, HBRSE nit No. 2
United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0092 Page 1 of 2 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REVISED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. (PEC), is proposing a change to Appendix A, Technical Specifications, of Facility Operating License No. DPR-23, for the H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2. The proposed change revises the requirements related to the reactor protection system interlock for the turbine trip input to the reactor protection system. The applicability note (f) for TS Table 3.3.1-1, Function 15, "Turbine Trip," is proposed to be revised from P-7 (Low Power Reactor Trips Block) to P-8 (Power Range Neutron Flux) interlock. This requires the associated Required Action P be revised to reduce thermal power to less than P-8 within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.
An evaluation of the proposed change has been performed in accordance with 10 CFR 50.91 (a)(1) regarding no significant hazards considerations, using the standards in 10 CFR 50.92(c). A discussion of these standards as they relate to this amendment request follows:
- 1.
The Proposed Change Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.
The proposed change provides revised requirements for the reactor protection system interlock associated with the turbine trip protection function. The proposed change will allow the interlock for turbine trip function to be raised from the current interlock setting of nominally 10 percent reactor power to nominally 40 percent reactor power.
This change will allow the reactor to continue operating safely at power levels up to nominally 40 percent when the turbine is not operating. The applicable accident analyses, as described in the HBRSEP, Unit No. 2, Updated Final Safety Analysis Report (UFSAR) have been reviewed. The turbine trip input to reactor trip has been verified to be either not used in the accident analyses or that the change does not adversely affect the analyses results and conclusion. Therefore, it is concluded that the consequences as described in the UFSAR accident analyses are unaffected by the proposed change.
An analysis of plant response to a turbine trip at nominally 40.percent power provided with the amendment request shows that the applicable acceptance criteria are met. Specifically, analysis has shown that a turbine trip without a reactor trip below 40 percent power does not challenge the pressurizer PORVs [power operated relief valves] or the steam generator safety valves; thereby, not adversely affecting the probability of a small break LOCA [loss of coolant accident] due to a stuck open PORV, or an excessive cooldown event due to a stuck open steam generator safety valve. As a result, the probability of any accident previously evaluated is not significantly increased by the proposed changes.
Therefore, operation of the facility in accordance with the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0092 Page 2 of 2
- 2.
The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident From Any Previously Evaluated.
As described above, the proposed change provides revised requirements for the reactor protection system interlock associated with the turbine trip protection function. The proposed change will allow the interlock for turbine trip function to be raised from the current interlock setting of nominally 10 percent reactor power to nominally 40 percent reactor power.
No new accident initiators or precursors are introduced by the proposed change. Changing the interlock for the reactor trip on turbine trip from P-7 to P-8 changes the power level associated with enabling and disabling the reactor trip on turbine trip function. The turbine pressure input to the reactor protection system permissive is not an accident initiator. The change does not affect how the associated trip functional units operate or function. The changes do not create the possibility of a new or different kind of accident from any previously evaluated because these interlock changes do not affect the way that the associated trip functional units operate or function Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any previously evaluated.
- 3.
The Proposed Change Does Not Involve a Significant Reduction in the Margin of Safety.
As described above, the proposed change provides revised requirements for the reactor protection system interlock associated with the turbine trip protection function. The proposed change will allow the interlock for the turbine trip function to be raised from the current interlock setting of nominally 10 percent reactor power to nominally 40 percent reactor power.
Also, as previously described, this change will allow the reactor to continue operating safely at power levels up to nominally 40 percent when the turbine is not operating. The applicable UFSAR accident analyses have been reviewed and it is concluded that the accident analyses are unaffected by the proposed change. An analysis of plant response to a turbine trip at nominally 40 percent power shows that the applicable acceptance criteria are met. Based on these evaluations, the margins of safety that could potentially have been impacted by the proposed change associated with the reactor, which include departure from nucleate boiling (DNB) and fuel temperature margins, and the margin of safety associated with reactor coolant system integrity, are not affected.
Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant reduction in the margin of safety.
Based on the above discussion, Carolina Power and Light Company has determined that the requested change does not involve a significant hazards consideration.