RNP-RA/13-0077, License Amendment Request for Technical Specification(Ts) Change to Use NRC-Approved TSTF-491, Revision 2, Removal of Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications

License Amendment Request for Technical Specification(Ts) Change to Use NRC-Approved TSTF-491, Revision 2, Removal of Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications

ML13283A012
Person / Time
Site:	Robinson
Issue date:	09/30/2013
From:	Wheeler-Peavyhouse S Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/13-0077
Download: ML13283A012 (14)

Text

Woutwu A. WAN Atew*se N a ReWOn Stem fobv*f R"~s 1" DUKE

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1519 Serial: RNP-RA/13-0077 10 CR 50.90 SEP 3 0 2013 ATTN: Document Control Desk U.S. Nucear Regulatory Commission WshiWgton, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 LICENSE AMENDMENT REQUEST FOR TECHNICAL SPECIFICATIONS (TS) CHANGE TO USE NRC-APPROVED TSTF-41, REVISION 2, REMOVAL OF MAIN STEAM AND MAIN FEEDWMTE YAW& MLAION TIMES MRM TE SP-ECIEFI1ATON

Dear r or Madam:

Pursuant to 10 CFR 50.90, Duke Energy Progress, Inc. fotmerly known as Carolin Power and Light Company, hereby requests Sn amendment to the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2) eWect facility operating license DPR-23, Appendix A, Technical Specifications.:

The proposed llcense amendment implements the NRC-approved TSTF-491, Removal of Main Steam and Main Feedwater Valve Isolation Times From Technical Specifications, via the Consolidated Line Item Improvement Process (C0IIP). This request wil modify the current HBRSEP Technical Specifications (TS) 3.7.2, Main Steam isolation Valves (MSIVs) and 3.7.3, Main Feedwatlr Isolation Valves (MFIVs), Main Feedwater Regulation Valves (MFRVs) and Bypass Valves by relocating the specific Isolation time for the isolation valves from the associated Surveillance Requirements (SR.). The specific Isolation times will be maintained In the HBRSEP2 Technical Requirements Manual (TRM).

The Enclosure provides the basis for the proposed change, including a detailed description, technical ind regulatory evaluations, environmental considerations, and the Duke Energy Progress, Inc. determination that the proposed change does not involve a significant hazards consideration. The proposed marked-up and retyped TS pages are provided in Attachments I and 2 to the Enclosure respectively. Mmrked-up TS Bases are included in Attachment 3 to the Enclosure for information.

Approval of the proposed amendment I requested by Septmber 30, 2014. Once approved, fte amendment shall be Implemented within 120 days.

A c

United States Nuclear Regulatory Commission Serial: RNP-RA/13-0077 Page 2 of 2 This proposed change has been reviewed by the HBRSEP2 Plant Nuclear Safety Committee.

This letter contains no new Regulatory Commitments.

In accordance with 10 CFR 50.91(b), a copy of this application isbeing provkded to the State of South Carolina.. If you should have any questions regarding this submittal, please oontact Mr.

Richard Hightoweir, Supeýisor -Regolatory Affairs at (843) 857-1329.

I declare under penalty of peury that the foregoing is true and correct. ExecutedOn:

+/-Sr 3U 30120 o Sincerely, Sharon A. WheelerAyhous*e*

Manager - Support Services - Nuclear

$W/PJmw Enclosur cc: Ms. S. E. Jenkin, Mange, Infectious and RadWio Wate Management Section (SC)

Mr. V. M. McCree, NRC Region II Mr. S. P. Lingam, NRC Pwrec Manager, NRR NRC Resident Inspectors, HBRSEP Mr. A. Wilson, Attomey General (SC)

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0077 Page I of 3 ENCLOSURE Evoluston of Pose Chang to Technical Spwft*on (TS) to Relocate te Main $team nd Main Feedwater Uowfn Valve Isolat Times to the TRM

2.0 ASSESSMENT

2.1 TMEA1, W B g

k 2.2

3.0 REGULATORY ANALYSIS

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"., I 3.2 VA tn &nW Uts 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

ATTACHMENTS:

I Poposed Tec:hnial Speikfls Charngs (Mrk-Up) 2 Roe d and Retyped Technical SpecIfIcato Page 3

Proposed Cthnges to Techrncal Specifications Baes Pages (Pomvded for information-Only)

United Stats Nuclear Regulatory Commission Enclosure to Serial: RNP-RAJ13-0071 Page 2 of 3 1.0 DESCtITON rhe 1prposed amendment would mdfy H. B.RobinsOn Steam Electric Plant, Unit No. 2 (HBRSEP2) Technical Specifications (TS) 3.7.2 (Mai Steam Isolatlo Valves) and TS 3.7.3 (Main Feedwater Isolation Valves, Main rFedweeftglion Valves, and Bypass Valves) by removing the specft Isolation time Ibr the Isolation v*ae from the associated T$ Surveillance Requirements ($R). ThbioattIn time In the TS SRs Is replaced with the requirement to veevy tho v"lv solatldin Wen Is *wlhl MWnls.

The Main Steam Isolation Valves and Main Foedwater Isolaton Valves, Main Feedwater Regulation Valves, and Bypass Valves specific Ioli times are provided In the Technical Requirements Manual (1'R). The TRM is st*ec to oonkol by the 10 CFR 50.50 proocs. Tre 10 CFR 50.59teria provide adequate a*urane ttrior NRC mvinew andapoval wilt be eques~terd fr hage o thTRM rq ireetsthathave the potential to affectthe safe operiatio of t Oplnt.

The changes to I4SSEP2 Tare cnitt thNuclea Regulatory commission (NRC) approved

-duuyednical Specification Task Force (TSTF) TSTF-4W1, Revision 2. The evallablilty of this TS, ' provsinent was publihe In fth Fedw&a Rgbtw o Deoember 29,202 as pert of t4 Cwsolidated Line Item Improvement P*ocess (CLIIP).

2.0 ASSESOME 2.1 Algi of T.

and Duke Energy Progress, ic: has reW edTSTF,4I(Fferenc* 1), and the NRC model saey evauthn (SE) (fWetk* 2)# as pttof the CUIP. Duke ney Prom, Inc.

has concluded thte InfOrmation InTTSTF-4 j1 as well as the SE prepared by the NRC utaff are applicable to 4BRSEP2 and ut Ill proposed amndment for the incorpratio of the changes to the NSRISMP T86, 2.2 I

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Duke Energy Progress, Inc. Is not proposing any variations or d*vio from the TS cages described 1 TSTF-491 Revision 2, or the NRC stafs model safety evaluation dated June 16, 2006.

3.0 REGULATOY ANALYSIS 3.1 NoftificAzrds Consideration Duke Enr~gy Pr~ogrs, Inc. has reviewed the proposed no significant hazads cnie8 o determination (NSHCD) published in the Federal Register as part of the CuIP. Duke Energly rogreas, Ic. has concued tht fth prp NSHM presented in the Federa gister notice is applicable to H.RSEP2 and is hereby Incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

United States Nuclear Regulatory Commission Enclosure to Serial: RNP.RN13-0077 Page 3 of 3.

3.2 Vedt AM Comminmt As discussed in the notice of availability published In the Federa Register on December 29, 2006 for this TS improvement, plant specific verifications were performed as follows:

The proposed change revises TS 3.7.2 and TS 3.7.3 surveillance requirements to remove specific valve Isolation times from the associated surveillances. The specific valve isolation times are replaced wth the requirements to verify the valve isolation is within limits. The specific valve *olatoiotime required to meet the surveillances is relocated outside of the TS into a document that is subject to control by the 10 CFR 50.59 process.

The Main Steam Isolation Valves, Main Feedwater Isolation Valves, Main Feedwater Regulation Valves, and Bypass Valves specific isolation times will be provided in the TRM, which is controlled by the 10 CFR 50.59 process. The proposed chwnge does not alter TS requirements for the Main Steam and Main Feedwater System isolation valves to be operable nor does, t change the TS requrent for the valves to isolate within the required time. As such, the proposed change is acceptable because It does not affect the assumptions of any accident analysis or TS compliance with the requirements of 10 CFR 50.38(cX2XU). The proposed change simply adjusts the level of detail contained In TS 3.7.2 and 3.7.3 to be more consistent with the requirements of other ESF equipment required operable in the HBRSEP TS.

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ENVIRONMENTAL EVALUATION The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CPR Pad 20. The NRC staff has determined that the amendment adop*n TSTF-491, Rev. 2, Involves no significant increase In the amounts and no significant changes in the types of any effluents that may be released offslte, and that there Is no significant Increase In individual or cumulative occupational radiation exposure. The Commission has previously issued a prOpoed finding that TSTF.491, Rev. 2, involves no significant hazards considerations, and there has been no public comment on the finding in Federal Register Not*c 71 FR 193, October 5, 2006. Accdig, the amend 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 5.0 REFERENCEs

1.

TSTF-491, Revislion 2, "Removal of Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications."

2.

NRC Model Safety Evaluation Report (FRN 71 FR 193, October 5, 2006).

Enclosure to Serial: RNP-RAl13-0077 3 Pages (Including cover page)

ATTACHMENT I H. 6. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UP)

MSIV3 3,7.2 ACTIONS ImnfntlnudI tO.iN A

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,:REQUIRED ACTION

.COMPLETION TIMJE D. ReOred Action and asscit Completion Time of Condition C not met.

0.1 Be in MODE 3.

D.2 b In MODE 4.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours SURVEILLANCE REQUIREMENTS II I III I

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SR 3.7.2.1 1,

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Oly re red to be performed In MOES I and 2.

Verify closure time of each MSIV is on "an actual or simulated actuation signal.

In accordance with the Inservice Tes" P

rUm HBRSEP Unit No. 2 3.7-7 Amerxknent No.

MFIVs, MFRVs, and Bypass Valves 3.7.3 Vý4 t1f] Z jr-T.

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C. One or more bypass C.1 Close or isolate bypass 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> valves Inoperable, valve.

C.2 Verify bypass valve Is Once per 7 days closed or Isolated.

0. Two va l Inte D.1 Isolate affected flow 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> same flow path Pat.

Inoperable.

E. Required Action and E.1 Be In MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not metA E.2 Be in MODE 4.

12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEIL ANCE REQUIREMENTS FREQUENCY SR 3.7.3.1 VeIfy the closure ttme of each MFRV and In accordance bypass valve Is on an actual or with the simulated actuation Signal.

ln vle Testing Program SR 3.7.3.2 Ve*fy the closure time of each MFIV is In accordance on an actual or simulated with the actuation signal.

Inervice Testing Program HBRSEP Unit No. 2 3.7-9 AmendnwW No.

Encosure to Serial: RNP-RAI3.0077 Attahmlent 2 3 PageO (Includng cover page)

ATTACHMENT 2 H. B. ROBINSOU STEAM ELECTRIC PLANT, UNIT NO. 2 REVISED AND AETYPLD TECHNICAL SPECIFICATIONS PAGES

MSIV$

3.7.2 Ar.Tk-M-q Itywitimm-Adl ONDITION.

REQUIRED ACTION COMPLETION TIME D. Requred Ationand associate CompWleton Tire of CondItion C not met.

0.1 Be In MODE 3.

0.2 Be in MODE 4.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours a

a SURVEILLANCE REQUIREMENTS U

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SR 3.7.2.1

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Onr requiedto be performed In MODES I nd 2.

Vefty closure time of each MSIV Is wlthin limits on an actual or imult

.~onsow.

In accordance with the Testing Program I

U HBRSEP Unit No. 2 3.7-7 Anwndmervt No.

MFIVs, MFRVs, and Bypass Valves 3.7.3 AfT1rKMQ 1f6^rwMMUw4%

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I ~iu lit/I iuIii i W Nu CONDITION REQUIRED ACTION COMPLETION TIME C. One or more bypass C.1 Closeorlsolatebypass 8hours valves Inoperable.

valve.

C.2 Verify bypass valve is Once per 7 days clded or Isolated.

D. Two valves In the D. t Isolate affected flow 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> same flow path path.

inoperable.

E. Required Action and asToimted Completion Time not met.

E.1 Be n MODE 3.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> E.2 BeIn MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> U

U SURVEILLANCE REQUIREMENTS..

SURBEILLANCE IFRUENCR SR 3.7.3.1 Verify the closure time of each MFRV and In accordance bypass valve Is within limits on an actual or with the simulated actuation signal.

Insrvice Testing Program SR 3.7.3.2 Verify the closure time of each MFIV is In accordance within limits on an actual or simulated with the actuation signal.

ervie Testing Program I

I HRSEP Unit No. 2 3.7-9 Amenchrient No.

Enclosure to Serial: RNP-RNI 3-0077 2 Pages (includIng cover page)

ATTACHMENT 3 H. a. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS BASES PAGES (Provided'for Information Only)

MSIVs 83.7.2 BASES ACTIONS C.and C.2 (continued)

Condition C Is modified by a Note Indicating that separate Condition entry Is allowed for each MSIV.

Since the MSIVs are required to be OPERABLE In MODES 2 and 3, the Inogp lo MSIVs may either be restored to OPERABLE status or closed. When closed, the MSlVs are already In the position required by the assumptions In the safety analysis.

The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time is reasonable, oonsidering the low probability' ofan'accident occurring during this time period that would require a closure of the NSIVs.

For inoperable MSIVsthat cannot be restored to OPERABLE status within the specified Completion Time, but are closed, the inoperable MSIVs nrust bevwrified on a periodic basis to be closed. This Is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Troe Is reasonable, based on engi mnt, in view of MSIV status indications available in the control room, and other administrave controls, to ensure that these valves are In the closed position.

Q.1 and 132 If th MSIVs cannot be" restoredto OPERABLE -Ot or are not closed w4hin the associated Completion'Time, the uri Imust be placed in a MODE in which the LCO does not apply. To achieve this st*tue the unit must be placed at least In MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, basd on operatn experience, to reach the required unit conditions from MODE 2 condltions In an orderly manner and without chalienging unit systems.

SURVEILLANCE SR 1

REQUIREMENTS This SR verifies that MSIV closure time is -

on an actual or simulated actuation signal. The maximum MSIV closure time Is less than that assumed In the accident and (continued)

HBRSEP Unit No. 2 83.7-12 Revision No.

MFIVs, MFRVs, and Bypass Valves 83.7.3

BASES (continued)

SURVEILLANCE REQUIREMENTS 9R 3.7.3.1 i

This SR verifies that the closure time of each MFRV and bypass valve Is

• on an actual or simulated actuation signal. The MFRV, and bypass valve closure times are assumed In the ascident and containment analyses (Ref.

2). This Surveillance is normally performed upon returning the unit to operation following a refueling outage. These valves should not be tested at power since even a part stroke exercise ncrmase the risk of a valve closure with the unit generating power. This is consistent with the ASME Code.Section X! (Ref. 3).

The Frequency for this SR Is in accordance with the Insee Testing Program. The specfied Frequency for valve closure is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when perfomd at the specified Frequency.

.ehlMl~ ~

This $R verifies that the closumre time of each MFIV Is Is on an actual or simulated actuation signal.

The MFIV closure times are assumed in the accident and contairment analyses (Ref. 2). This Surveillance is normally performed upon returning the unit to operation following a refueling outage. These valves should not be tested at power since even a part stroke exercise Increases the risk of a valve closure with the unit generating power.

This Is consistent with the ASME Code,Section XI (Ref. 3).

The Frequency for this SR is In acordance with the Inservice Testing Program. The specified Frequency for valve closure is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the specified Frequency.

(continued)

HBRSEP Unit No. 2 B83.7-19 Revision No.,