ML100830330

Issuance of Amendment Regarding Technical Specifications Changes Related to the Chemical and Volume Control System

ML100830330
Person / Time
Site:	Robinson
Issue date:	03/25/2010
From:	Orf T Plant Licensing Branch II
To:	Mccartney E Carolina Power & Light Co
Orf, T J, NRR/DORL/301-415-2788
References
TAC ME3550
Download: ML100830330 (20)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 25, 2010 Mr. Eric McCartney, Vice President H. B. Robinson Steam Electric Plant, Unit NO.2 Carolina Power &Light Company 3581 West Entrance Road Hartsville, South Carolina 29550-0790 SUB~IECT:

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 - ISSUANCE OF AMENDMENT REGARDING TECHNICAL SPECIFICATIONS CHANGES RELATED TO THE CHEMICAL AND VOLUME CONTROL SYSTEM (TAC NO. ME3550)

Dear Mr. McCartney:

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 223 to Renewed Facility Operating License No. DPR-23 for the H.B. Robinson Steam Electric Plant, Unit No.2, in response to your application dated March 22, 2010, as supplemented by letter dated March 23,2010. The amendment consists of changes to Technical Specification (TS)

Section 3.4.17, "Chemical and Volume Control System (CVCS)."

The amendment changes TS 3.4.17 to revise the requirements related to the makeup water pathways from the refueling water storage tank. Specifically, the change revises the required completion time on a temporary basis for TS 3.4.17, Action B.1, from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the remainder of fuel cycle 26.

A copy of the related safety evaluation is also enclosed. The notice of issuance will be included in the NRC's next biweekly Federal Register notice.

Sincerely,

~r~

Tracy J. Orf, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosures:

1. Amendment No. 223 to DPR-23

2. Safety Evaluation cc w/enclosures: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 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. 223 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 March 22, 2010, as supplemented by letter dated March 23, 2010, 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 Title 10 of the Code of Federal Regulations (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 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

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. 223 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 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

~~fu Plant Licensing Branch 11-2 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:

March 25, 2010

ATTACHMENT TO LICENSE AMENDMENT NO. 223 RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace page 3 of Renewed Operating License No. DPR-23 with the attached page 3.

Replace the following page of Appendix A of the Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3.4-49 3.4-49

- 3 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. 223 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. 223

CVCS 3.4.17 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.17 Chemical and Volume Control System (CVCS)

LCO 3.4.17 Reactor Coolant Pump (RCP) seal injection shall be OPERABLE, with:

a.

Two charging pumps shall be OPERABLE; and

b.

Two Makeup Water Pathways from the Refueling Water Storage Tank (RWST) shall be OPERABLE.

APPLICABILITY:

MODES I, 2, 3, and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One required charging pump inoperable.

A.1 Restore required charging pump to OPERABLE status.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> B.

One Makeup Water Pathway from the RWST inoperable.

B.1 Restore Makeup Water Pathway from the RWST to OPERABLE status.

24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s*

C.

Required Action and associated Completion Time of Condition A or B not met.

C.1 AND C.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours (continued)

• The Completion Time for Required Action B.1 to Restore Makeup Water Pathway from the RWST to OPERABLE status is allowed to be 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during Operating Cycle 26.

HBRSEP Unit No. 2 3.4-49 Amendment No. 223

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 223 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 letter dated March 22, 2010, as supplemented on March 23, 2010, Carolina Power & Light Company (the licensee), now doing business as Progress Energy Carolinas, Inc., proposed changes to the Technical Specifications (TSs) for H. B. Robinson Steam Electric Plant (HBRSEP), Unit 2. The amendment would modify the TSs in that it would change the completion time associated with required actions for Limiting Condition for Operation (LCO) 3.4.17.B.

TS 3.4.17, "Chemical and Volume Control System (CVCS)," requires that reactor coolant pump (RCP) seal injection shall be operable, with two operable charging pumps and two operable makeup water pathways from the refueling water storage tank (RWST).

Currently, LCO 3.4.17.B requires, in the event that one makeup water pathway from the RWST is inoperable, the restoration of the RWST makeup water pathway to an operable status with an associated completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This license amendment extends the completion time associated with the required action for LCO 3.4.17.8 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The change is requested on an emergency basis in order to provide adequate time to correct a degraded condition. Specifically, a pipe in one of the RWST injection pathways is leaking, and the pathway will need to be declared inoperable while repairs are undertaken. It is expected that the repair will take slightly longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

A supplemental letter provided by the licensee on March 24, 2010 clarified that the request is for a one-time change. The extension to the completion time is only applicable until the end of the current fuel cycle, at which point the completion time will return to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

1.1

Background:

CVCS Description and Makeup Sources The function of the CVCS is to provide a source of borated makeup water to the reactor coolant system (RCS) at operating temperatures and pressures. The CVCS also provides cooling water

- 2 injection to the RCP seals and has the additional functions of removing impurities in the RCS, controlling reactor coolant chemistry, and controlling RCS inventory of both boron and coolant during heatup and cooldown of the reactor.

It is necessary to provide adequate seal cooling to the RCPs, consistent with TS 3.4.17.

Without this cooling, the pump seals could degrade and begin leaking primary coolant at a rate in excess of the makeup capacity of the charging system. The consequences of this postulated evolution are expected to be analogous to a small break loss-of-coolant accident.

The function of the RCP seals is further addressed in the HBRSEP Updated Final Safety Analysis Report (UFSAR) Section 5.2, "Integrity of the Reactor Coolant Pressure Boundary,"

Subsection 3.1.2, "Reactor Coolant Pump Seals." The UFSAR states that the leakoff system between NO.2 and NO.3 seals is considered to be part of the RCS. The leakoff system collects leakage passed by the NO.2 seal, provides a constant backpressure on the NO.2 seal and constant pressure on the No.3 seal.

USFAR Section 5.4.1, "Reactor Coolant Pumps," describes the seal cooling function. A portion of the high pressure water flow from the charging pumps is injected into the RCP between the impeller and the controlled leakage seal. Part of the flow enters the RCS through a labyrinth seal in the lower pump shaft to serve as a buffer to keep reactor coolant from entering the upper portion of the pump.

Finally, UFSAR Section 9.3.4, "Chemical and Volume Control System," states the design bases for the CVCS. Among these, the CVCS provides the required seal water flow for the RCP shaft seals.

At HBRSEP, makeup water to the RCS is provided by the CVCS from the following sources:

(1)

The primary water storage tank, which provides water for dilution when the reactor coolant boron concentration is to be reduced; (2)

The boric acid tanks, which supply concentrated boric acid solution when reactor coolant boron concentration is to be increased; (3)

The RWST, which supplies borated water for emergency makeup through two redundant pathways; and (4)

The chemical mixing tank, which is used to inject small quantities of solution when additions of hydrazine or pH control chemical are necessary.

Items 1 through 3 of this list provide the necessary flow for RCP seal injection; Item 4 is not considered as a possible source of RCP seal injection flow because it is used to inject small quantities of a solution. The abundance of available sources for RCP seal cooling through the diverse and redundant supplies provides assurance that adequate RCP seal cooling is provided, and that the CVCS can meet its design basis requirement to provide seal water flow for the RCP shaft seals. This function serves the safety-significant purpose of maintaining the reactor coolant pressure boundary.

-3

2.0 REGULATORY EVALUATION

The CVCS seal injection function must have LCOs prescribed for it because it satisfies Criterion 4 of Title 10 of the Code of Federal Regulations (10 CFR) 50.36(c)(2)(ii). For its seal injection function, the CVCS is a structure, system, or component that operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

As stated above, there are three possible sources of makeup water for the CVCS. The fourth, the chemical mixing tank, is not considered, because it is intended to inject small quantities of chemical solutions.

Of the three sources, the two pathways from the RWST are the only ones required to be operational per facility TSs. The TSs require two independent makeup water pathways from the RWST.

3.0 TECHNICAL EVALUATION

3.1 Summary of Technical Information in the License Amendment Request The licensee's request is specifically to modify TS 3.4.17, "Chemical and Volume Control System (CVCS)," which requires two makeup water pathways from the RWST to be operable, as follows:

Currently, LCO 3.4.17, Action B.1, requires the restoration of the makeup water pathway from the RWST within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under the condition of a single inoperable makeup water pathway from the RWST. The completion time is proposed to be revised to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the remainder of fuel cycle 26.

The licensee stated that the proposed completion time is justified based on the low safety significance of the loss of one of the RWST makeup water pathways. The normal water supply to the charging pumps that provide RCP seal injection flow comes from the volume control tank (VCT). The VCT is normally replenished by the primary water storage tank, in combination with boric acid storage tanks, for makeup and RCS boron concentration adjustments. The pathways from the RWST are not normally used to supply seal injection during operation and provide the back-up source of fluid if the normal sources become unavailable. In addition to the two makeup water pathways from the RWST that are addressed by TS 3.4.17, and the normal source from the VCT, fluid for seal injection via the charging pumps can be supplied from both normal and emergency boration paths.

In a supplemental letter dated March 24, 2010, the licensee provided additional information.

This additional information clarified that the request is submitted with applicability only to the end of the current fuel cycle, and provided Technical Requirements pertaining to the boric acid and primary water storage tank, two alternate sources of RCP seal injection flow.

3.2 Technical Evaluation The licensee's request is based on an abundance of alternate makeup water supplies available, should the RWST supply pathways become inoperable.

-4 In its normal, TS-required configuration, the CVCS is providing makeup flow from the volume control tank, as supplied by the primary water storage tank. The operable RWST supply pathways provide two, TS-required, redundant alternatives, should the normal supply become unavailable.

Upon entry into Condition B of LCO 3.4.17, the plant currently may spend 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a condition with only a single, TS-required makeup source from the RWST. The licensee proposes to extend this condition to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The licensee's justification is based on the fact that additional sources of makeup for the CVCS are available, although not required by TS.

Namely, the normal and emergency boration paths provide a level of defense-in-depth to preclude the loss of both RWST makeup pathways, in combination with a loss of the VCT source, from causing a condition that could challenge the integrity of the RCP seals. Because of this level of defense-in-depth, the licensee states that an extension from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the required action to restore a single, inoperable RWST makeup water pathway to the CVCS is acceptable.

The regulatory requirement is based on risk analysis or operating experience having shown that the required makeup alignment to the RWST is important to public health and safety. While the licensee's justification identifies alternative makeup sources, the operability of these sources is not required by the TS, and the licensee's risk analysis was not evaluated by the NRC staff, since the submittal was not risk-informed.

The NRC staff considered whether there was reasonable assurance that seal flow could be maintained in a condition where the CVCS makeup pathways were degraded further than the single RWST pathway inoperable condition that presently exists.

Although these sources are not explicitly required by the TS, Technical Requirements require the operability of the boric acid pumps, the boric acid tanks, and heat tracing equipment for the flow path from the boric acid tanks. In light of these requirements, there is reasonable assurance that at least the boric acid injection flowpath to the charging pumps will be maintained.

Seal injection and makeup flow from the VCT is the normally aligned pathway for the CVCS.

Therefore, an issue affecting the operability of this makeup pathway would be self indicating by deviations from expected parameters in any of the volume control tank, the seal water supply, or the charging water system.

The NRC finds the licensee's request to extend the completion time associated with LCO 3.4.17.B from 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> acceptable. The NRC staff's finding, as described above, is based on the following considerations:

(1)

Should the remaining TS-required RWST injection pathway become inoperable, LCO 3.4.17 prescribes appropriate action to place the plant in a safe condition; (2)

Alternate sources of seal injection flow are available beyond the TS-required makeup source from the RWST; and

- 5 (3)

The alternate sources of seal injection flow are required by administratively controlled procedures or are currently in use, such that issues affecting their operability would be self-revealing.

Because of the reasonable degree of assurance that a source of CVCS makeup flow will be provided while repairs to the RWST pathway are undertaken, the intent of the TS is still met in that RCP seal injection remains operable, and the temporarily extended LCO completion time continues to meet the intent of 10 CFR 50.36(c)(2)(ii), in that an acceptable LCO is still provided for seal injection flow, which plant experience and/or risk analysis has shown to be important to safety.

3.3 NRC Staff's Conclusion Based on the considerations discussed above, the NRC staff concludes that there is reasonable assurance that the requested one-time extension to the completion time to LCO 3.4.17.B is acceptable. The licensee may extend the completion time from 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to allow for the timely repair of a leaking pipe on one of the TS-required RWST makeup flow paths, remaining in compliance with Criterion 4 of 10 CFR 50.36(c)(2)(ii).

4.0 EMERGENCY CIRCUMSTANCES The need for the emergency approval of the proposed amendment results from the unexpected development of a leak in one of the makeup flow paths from the RWST. On March 16, 2010, a leak via a through-wall defect in a connection between the 4-inch makeup flow piping to a 314-inch drain line was discovered after noting a decreasing trend in VCT level. The leak rate was within allowable limits and a structural analysis of the measured defect determined that structural integrity was maintained. At approximately 08:10 hours on March 18, 2010, it was noted that the leak rate had increased and the flaw length had increased. The flaw length was approaching a value that would require declaring the piping inoperable, and hence would require entry into TS 3.4.17, Condition B. The visible surface flaw indication was initially measured at about 1.25 inches on March 16, 2010. The flaw size was estimated to be about 1.625 inches on March 18, 2010, with a calculated operability limit of 1.79 inches.

A temporary modification consisting of a mechanical brace was designed to limit propagation of the crack by reducing vibration of the drain line. The mechanical brace was installed at approximately 13:30 hours on March 18, 2010, to stop or slow the progression of the flaw.

Given the high likelihood that that the flaw could further degrade and exceed operability criteria, repair options for the leak were being planned. The repair options require the removal of one RWST pathway from service by use of one or more freeze seals in this line. In this condition with the line isolated, entry into TS 3.4.17, Condition B, is required. The repair options have a high likelihood of exceeding the current TS 3.4.17 required Action B.1 completion time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Therefore, the current TS would likely result in the need for a plant shutdown during the repair of this piping. It is expected that the requested 72-hour completion time would allow sufficient time for repairs without the need for a plant shutdown.

Therefore, the proposed change is necessary to allow repair to this unexpected condition by minimizing the likelihood of plant shutdown transient while the repair is conducted. This

- 5 situation could not be avoided due to the unforeseen circumstance of a through-wall crack at this location.

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

The Commission may issue license amendments before the expiration of the 50-day period provided that its final determination is that the amendments involve no significant hazards consideration. These amendments are being issued prior to the expiration of the 50-day period.

Therefore, a final finding of no significant hazards consideration follows.

The Commission has made a final determination that the amendment request involves no significant hazards consideration. Under the Commission's regulations in 10 CFR 50.92, this means that operation of the facility in accordance with the proposed amendment does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. As required by 10 CFR 50.91 (a), the licensee has provided in its letter of March 22, 2010, as supplemented on March 23, 2010, its analysis of the issue of no significant hazards consideration, which is presented below:

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 completion time of the action required when one makeup water flow path from the RWST to the charging pumps for RCP seal injection is inoperable. The revised requirements are appropriate because other conditions in this same LCO (Conditions D and E) already provide requirements for immediate action to restore RCP seal injection flow if it is not within the required limit. The increase in completion time from 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the condition with one RWST pathway inoperable is consistent with other similar restrictions applied to a loss of redundancy. Therefore the proposed change has minimal impact on the probability of accidents that may occur as a result of the loss of RCP seal cooling. Based on the Updated Final Safety Analysis Report descriptions for the CVCS system, the makeup water flow paths are not required for accident consequence mitigation and hence there is no impact on the consequences of analyzed accidents.

Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident From Any Previously Evaluated.

The proposed change provides revised requirements for the completion time of the action required when one makeup water flow path from the

- 7 RWST to the charging pumps for RCP seal injection is inoperable. The TS Section 3.4.17 LCO requirements are intended to provide appropriate requirements and limitations to reduce the likelihood of a loss of coolant accident that could be caused a loss of RCP seal cooling. The proposed TS Section 3.4.17 requirements will continue to maintain appropriate requirements and limitations for the CVCS. The proposed changes to the completion time limits for TS LCO 3.4.17 do not affect the manner that this equipment performs such that a new or different type of failure mode or accident would be created. Additionally, no new accident initiators, precursors, or sequences are introduced by the proposed change because only the time limits associated with currently postulated conditions are being changed.

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.

The proposed change provides revised requirements for the completion time of the action required when one makeup water flow path from the RWST to the charging pumps for RCP seal injection is inoperable. There is no specifically identified margin of safety associated with this function and the time limits established for completing required actions in LCO 3.4.17. Increasing the completion time limits associated with inoperability of one RWST flow path does not result in a change that would impact the progression of an accident or malfunction as described in the Updated Final Safety Analysis Report. The requirements of LCO 3.4.17 are intended to maintain the RCP seal cooling function and provide appropriate limitations on reactor operation if the requirements are not met. The proposed changes for LCO 3.4.17 will continue to maintain appropriate requirements for this function. The proposed changes to LCO 3.4.17 do not impact the other TS requirements that provide appropriate limitations on the systems that would protect the margin of safety in the unlikely condition that RCP seal cooling cannot be maintained within limits.

Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant reduction in the margin of safety.

The NRC staff has reviewed the licensee's analysis and based on this review, determined that the three standards of 10 CFR 50.92 are satisfied. Therefore, the NRC staff has determined that the amendment involves no significant hazards consideration.

- 8

6.0 STATE CONSULTATION

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

7.0 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. 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 made a final no significant hazards finding with respect to this amendment.

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.

8.0 CONCLUSION

The NRC has concluded, based on the considerations discussed above, that (1) the amendment does not: (a) involve a significant increase in the probability or consequences of an accident previously evaluated; or, (b) create the possibility of a new or different kind of accident from any previously evaluated; or, (c) involve a significant reduction in a margin of safety and therefore, the amendment does not involve a significant hazards consideration; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (3) such activities will be conducted in compliance with the Commission's regulations, and (4) 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: Benjamin Parks Date:

March 25, 2010

March 25, 2010 Mr. Eric McCartney, 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 TECHNICAL SPECIFICATIONS CHANGES RELATED TO THE CHEMICAL AND VOLUME CONTROL SYSTEM (TAC NO. ME3550)

Dear Mr. McCartney:

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 223 to Renewed Facility Operating License No. DPR-23 for the H.B. Robinson Steam Electric Plant, Unit No.2, in response to your application dated March 22, 2010, as supplemented by letter dated March 23, 2010. The amendment consists of changes to Technical Specification (TS)

Section 3.4.17, "Chemical and Volume Control System (CVCS)."

The amendment changes TS 3.4.17 to revise the requirements related to the makeup water pathways from the refueling water storage tank. Specifically, the change revises the required completion time on a temporary basis for TS 3.4.17, Action B.1, from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the remainder of fuel cycle 26.

A copy of the related safety evaluation is also enclosed. The notice of issuance will be included in the NRC's next biweekly Federal Register notice.

Sincerely, IRA!

Tracy J. Ort, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosures:

1. Amendment No. 223 to DPR-23

2. Safety Evaluation cc w/enclosures: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL2-2 r/f RidsOgcRp RidsNrrPMRobinson RidsAcrsAcnw_MailCTR RidsNrrDorlLPL2-2 RidsNrrLACSola RidsRgn2MailCenter RidsNrrDirsltsb RidsNrrDorlDpr RidsNrrDssSrxb, BParks, NRR ADAMS Accession Number" ML100830330 NRR-058 OFFICE LPL2-2/PM LPL2-2/LA SRXB/BC ITSB/BC OGC (NLO)*

LPL2-2/BC (A) LPL2-2/PM NAME TOrf RSoia GCranston RElliott LSubin BMozafari for DBroaddus TOrf DATE 3/24/10 3/24/10 3/24/10 3/24/10 3/25/10 3/25/10 3/25/10

• with comments OFFICIAL RECORD COpy