ML120730281

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Issuance of an Amendment Regarding Technical Specification Changes to Section 3.8.3, Diesel Fuel Oil and Starting Air, and Section 3.8.5, DC Sources- Shutdown
ML120730281
Person / Time
Site: Robinson 
Issue date: 03/30/2012
From: Billoch-Colon A
Plant Licensing Branch II
To: Duncan R
Carolina Power & Light Co
Billoch-Colon A, NRR/DORL, 301-415-3302
References
TAC ME5408
Download: ML120730281 (12)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 30, 2012 Mr. Robert J. Duncan II, 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 REGARDING TECHNICAL SPECIFICATIONS CHANGES TO SECTION 3.8.3, DIESEL FUEL OIL AND STARTING AIR, AND SECTION 3.8.5, DC SOURCES - SHUTDOWN (TAC NO. ME5408)

Dear Mr. Duncan:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 228 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP). This amendment is in response to your application dated January 20, 2011 (Agencywide Documents Access and Management System Accession No. ML110310012), as supplemented by letter dated February 23,2012 (ML120680168).

The amendment revises HBRSEP Technical Specifications (TS) TS 3.8.3, "Diesel Fuel Oil and Starting Air," Condition D, changing the emergency diesel generator starting air receiver low air pressure limit from 100 pounds per square inch gauge (psig) to 150 psig, and corrects an editorial error related to the numbering format in TS 3.8.5, "DC Sources - Shutdown," Limiting Condition for Operation (LCO) Condition A, Required Action from A.1.1 to A.1.

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

~1.~~

Araceli T. Billoch Colon, 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. 228 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. 228 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 January 20,2011, as supplemented by letter dated February 23, 2012, 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

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. 228 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 Douglas A. Broaddus, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Operating License No. DPR-23 and the Technical Specifications Date of Issuance: March 30, 2012

ATTACHMENT TO LICENSE AMENDMENT NO. 228 RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace the following pages of the Renewed Facility Operating License and Appendix "A" Technical Specifications with the enclosed pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove License DPR-23 License DPR-23 Page 3 Page 3 TSs TSs 3.8-17 3.8-17 3.8-22 3.8-22

- 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. 228 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.228

Diesel Fuel Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DGs with new fuel oil properties not within limits.

C.1 Restore stored fuel oil properties to within limits.

30 days D. One or more DGs with starting air receiver pressure < 210 psig and

~ 150 psig.

0.1 Restore starting air receiver pressure to

~ 210 psig.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> E. Required Action and associated Completion Time not met.

OR Common stored DGs

. diesel fuel oil or starting air subsystem for each DG not within limits for reasons other than Condition A. B. C. or D.

E.1 Declare associated DG(s) inoperable.

Immediately HBRSEP Unit No.2 3.8-17 Amendment No. 228 I

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER. SYSTEMS 3.8.5 DC Sources - Shutdown LCD 3.8.5 DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY:

MODES 5 and 6, and During movement of irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more required DC electrical power subsystems inoperable.

A.1 OR A.2.1 Declare affected required feature( s) inoperable.

Suspend CORE ALTERATIONS.

A.2.2 Suspend movement of irradiated fuel assemblies.

Immediately Immediately Immediately (continued)

HBRSEP Unit No.2 3.8-22 Amendment No. 22q

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 228 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-23 CAROLINA POWER &LIGHT COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 DOCKET NO. SO-261

1.0 INTRODUCTION

By letter to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated January 20, 2011 (Agencywide Documents Access and Management System Accession No ML110310012), as supplemented by a letter dated February 23,2012 (ML120680168),

Carolina Power & Light Company (the licensee), doing business as Progress Energy Carolinas requested changes to the Technical Specifications (TSs) for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).

The proposed changes (1) modify TS 3.8.3, "Diesel Fuel Oil and Starting Air," Condition D, changing the emergency diesel generator (EDG) starting air receiver low air pressure limit from 100 pounds per square inch gauge (psig) to 1S0 psig, and (2) corrects an editorial error related to the numbering format in TS 3.8.S, "DC Sources - Shutdown," Limiting Condition for Operation (LCO) Condition A, Required Action from A.1.1 to A.1.

The February 23, 2012, supplement provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs initial proposed no significant hazards consideration, as published in the Federal Register.

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. These TSs are derived from the plant safety analyses. The NRC's 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, "Technical specifications."

Pursuant to 10 CFR SO.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (S) administrative controls. The rule does not specify the particular requirements to be included in a plant's TSs. The regulations in 10 CFR SO.36(c)(2)(i),

"Limiting conditions for operations," state, in part, that:

- 2 Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The onsite electrical power system includes standby power sources, distribution systems, and vital auxiliary supporting systems to supply power to safety-related equipment. Most commercial nuclear power plants use EDGs as standby emergency alternate current power sources for the safety-related electrical buses. The importance of the diesel generators (or other standby power sources) is reflected in their incorporation NRC regulations, TSs, and other regulatory programs, including the General Design Criterion (GDC) 17, "Electric Power Systems" of Appendix A "General Design Criteria for Nuclear Power Plants" and Appendix B "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants to 10 CFR Part SO.

3.0 TECHNICAL EVALUATION

3.1 Basis for the Proposed TS Changes The licensee proposed to modify the EDG minimum air start receiver low pressure limit, as specified in Condition 0 of TS 3.8.3, from a value of a 100 psig to 1S0 psig. In the letter dated January 20, 2011, the licensee stated that the 100 psig value is nonconservative with the EDG vendor, Fairbanks Morse, recommendation of a minimum air pressure of 1S0 psig to ensure a reliable EDG start. TS 3.8.3 requires that the EDG starting air receiver pressure be maintained greater than or equal to 210 psig, which is verified by TS Surveillance Requirement (SR) 3.8.3.3.

The licensee also stated that the purpose of the lower speci'fied pressure (100 psig being changed to 1S0 psig) is to allow for an extension of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to having to declare the EDG inoperable, based on the assessment that the minimum pressure will be sufficient for a reliable start with one attempt. The proposed TS change will make the TS 3.8.3 requirement consistent with the licensee's vendor, Fairbanks Morse, recommendation.

Section 9.S.6, "Emergency Diesel Engine Starting System," of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," states that one of the specific criteria necessary for the EDG starting air system to meet the independence and redundancy criteria of GDC 17 is that the starting air system should be capable of cranking a cold diesel engine five times without recharging the receiver(s). In Section 8.3.1.1.S.1 of the HBRSEP Updated Final Safety Analysis Report, the licensee stated that each EDG has compressed air storage sufficient for eight cold diesel engine starts.

By Jetter dated February 23,2012, the licensee provided the calculation RNP-M/MECH-181S, Revision 1, "Evaluation of Emergency Diesel Generator Starting Capability at 1S0 psig," which provides the analysis to validate that the 1S0 psig would provide reliable starting capability for the HBRSEP EDGs. The licensee stated that the calculation determined the amount of available energy contained in the air receiver at a pressure of 1S0 psig was approximately twice the energy (7S,000 foot (ft.) Ibf (pounds force) versus 38,000 ft. Ibf) available at an air receiver pressure of 120 psig, which was used in a successful start during the initial startup testing.

Therefore, the amount of air in the air receiver at 1S0 psig provides sufficient energy to ensure a reliable start for the HBRSEP EDGs.

- 3 The licensee also proposed to correct an editorial error related to the numbering format in TS 3.8.5, "DC Sources - Shutdown," Limiting Condition for Operation (LCO) Condition A, Required Action from A 1.1 to A 1. The NRC staff has determined that the proposed TS changes are acceptable as discussed below.

3.2 NRC Staff Evaluation of Proposed TS Changes The proposed amendment would modify the TS requirements related to TS 3.8.3, Condition D, by changing the lower limit of air pressure in the starting air receiver from 100 psig to 150 psig and TS 3.8.5 by changing the numbering of Required Action A 1.1 to A 1.

The proposed change to TS 3.8.3, Condition D would increase the minimum air pressure in the starting air receiver to be in compliance with the vendor's, Fairbanks Morse's, recommendation for minimum starting air pressure to expect a reliable EDG start. The licensee performed calculation RNP-M/MECH-1815, Revision 1, to justify the Fairbanks Morse recommendation that a minimum air pressure of 150 psig in the starting air receiver will ensure a reliable start for each EDG. The calculation used historical data from initial startup testing of the "B" EDG to evaluate a proposed engine lockout after a 20 second overcrank with a failure to start. After the simulated failure to start, the air pressure in the starting air receiver was 120 psig. The engine was then successfully started with the 120 psig air pressure, and the air pressure in the starting air receiver was noted to be 110 pSig after the successful start. The licensee calculated the amount of stored energy in the air receiver expended to start the engine at an initial air receiver pressure of 120 psig, and also calculated the amount of stored energy in the air receiver at a pressure of 150 psig. The calculation showed that the amount of stored energy in the air receiver at a pressure of 150 pSig is approximately twice the amount of energy expended during the initial startup testing of the "B" EDG with an air receiver pressure of 120 psig.

The differences in starting the EDG after a 20 second overcrank (as in the initial startup testing) and starting the EDG with no prior start are mainly the differences in the static and dynamic (sliding) coefficients of friction and differences in the initial temperature of the EDG. There should be little difference in the dynamic coefficients of friction between the two types of starts because the engine rolled, but was not started during the 20 second overcrank period of the initial startup test, and very little engine heatup would have occurred. Therefore, the main difference between a 150 psig start with no prior starts and the 120 psig start after the 20 second overcrank would be the reduction of the static coefficient of friction caused by the 20 second overcrank. This difference should be minimal because each EDG is operated monthly for at least 60 minutes per TS SR 3.8.1.3. Also, each EDG has a lube oil keepwarm system and a jacket water keepwarm system that keep the lube oil and jacket water at minimum temperatures of 130 degrees Fahrenheit CF) and 110°F, respectively. Based on this evaluation, the NRC staff finds that an air pressure of 150 psig in the starting air receiver is sufficient to provide a reliable EDG start.

The proposed change to TS 3.8.5, Condition A, would correct an editorial error related to TS formatting. Condition 3.8.5.A is "One or more required DC [direct current] electrical power subsystems inoperable." It has a Required Action of "A1.1 - Declare affected required feature(s) inoperable," which is followed by allowed alternate actions A2.1 through A2.4. The licensee is proposing to change "A1.1" to "A1" for consistency in TS formatting. This requested change is editorial only and does not affect any system, structure, or component, and it does not

- 4 affect plant operation. The NRC staff finds this editorial change acceptable.

3.3 Conclusion Based on the above evaluation, the NRC staff finds that the licensee has provided adequate justification for the proposed changes to the HBRSEP TSs. Therefore, the proposed changes to TS 3.8.3 Condition D and TS 3.8.5 Condition A are acceptable.

4.0 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.

5.0 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 previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding, which was published in the Federal Regisieron April 19,2011 (76 FR 21922). 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 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: Robert Wolfgang Date:

March 30, 2012

March 30, 2012 Mr. Robert J. Duncan II, 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 REGARDING TECHNICAL SPECIFICATIONS CHANGES TO SECTION 3.8.3, DIESEL FUEL OIL AND STARTING AIR, AND SECTION 3.8.5, DC SOURCES - SHUTDOWN (TAC NO. ME5408)

Dear Mr. Duncan:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 228 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP). This amendment is in response to your application dated January 20, 2011 (Agencywide Documents Access and Management System Accession No. ML110310012), as supplemented by letter dated February 23,2012 (ML120680168).

The amendment revises HBRSEP Technical Specifications (TS) TS 3.8.3, "Diesel Fuel Oil and Starting Air," Condition D, changing the emergency diesel generator starting air receiver low air pressure limit from 100 pounds per square inch gauge (psig) to 150 psig, and corrects an editorial error related to the numbering format in TS 3.8.5, "DC Sources - Shutdown," Limiting Condition for Operation (LCO) Condition A, Required Action from A 1.1 to A 1.

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, IRA!

Araceli 1. Billoch Col6n, 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. 228 to DPR-23
2. Safety Evaluation cc w/enclosures: Distribution via ListServ DISTRIBUTION:

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