ML14069A387

NRR E-mail Capture - H. B. Robinson Steam Electric Plant Unit No. 2 - Requests for Additional Information (Rais) for License Amendment Request to Modify TS 3.4.12, Low Temperature Overpressure Protection System

ML14069A387
Person / Time
Site:	Robinson
Issue date:	03/10/2014
From:	Siva Lingam Plant Licensing Branch II
To:	Hightower R Progress Energy Co
References
MF2718
Download: ML14069A387 (3)

Text

NRR-PMDAPEm Resource From: Lingam, Siva Sent: Monday, March 10, 2014 7:18 AM To: richard.hightower@pgnmail.com Cc: Quichocho, Jessie; Jackson, Christopher; Hardgrove, Matthew; Parks, Benjamin; Grover, Ravinder

Subject:

H. B. Robinson Steam Electric Plant Unit No. 2 - Requests for Additional Information (RAIs) for License Amendment Request to Modify TS 3.4.12, Low Temperature Overpressure Protection System (TAC No. MF2718)

Please note the official RAIs for the subject LAR. Please provide your responses within 30 days.

By letter dated September 10, 2013, Duke Energy Progress, Inc., the licensee, submitted a license amendment request (LAR). The proposed amendment would modify Technical Specification (TS) Surveillance Requirement (SR) 3.4.12.6 of TS 3.4.12, Low Temperature Overpressure Protection (LTOP) System, with a Note that does not require that the surveillance be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing the reactor coolant system (RCS) cold leg temperature to less than or equal to 350 oF. In addition, the FREQUENCY requirement would be modified to simply 31 days.

Based on the its review of the amendment request, the Nuclear Regulatory Commission (NRC) staff has determined that additional information is required regarding the Note to TS SR 3.4.12.6 and FREQUENCY modifications.

SRXB - RAI 1 Please provide justification for adoption of NUREG-1431, Revision 3, Standard Technical Specifications Westinghouse Plants, for TS SR 3.4.12.6 of TS 3.4.12, LTOP System. Please also provide a safety basis for the modification. This basis may include procedural controls, operator training, and related considerations.

The basis may also include similar considerations that show that the consequences of such a simultaneous actuation are reasonably mitigated.

SRXB - RAI 2 In the LAR, it is stated that there is a low probability for a low temperature overpressure event within this limited time period. The NRC staff notes that the LTOP will be armed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in MODE 4, without a surveillance requirement verifying the operability of the power-operated relief valves (PORVs) instrumentation.

Please provide additional detail about the low probability of a low temperature overpressure event occurrences by describing plant operational experience with LTOP events. How many LTOP events have occurred, and if any have occurred, have they occurred within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entry into MODE 4?

SRXB - RAI 3 TS SR 3.4.12.6 is for the channel operational test to verify the PORV lift setpoint is within the maximum limits in the LTOP analyses and, as necessary, adjust the lift setpoint. Please provide any missed or failed surveillances related to TS SR 3.4.12.6.

From: Lingam, Siva Sent: Tuesday, December 31, 2013 8:42 AM To: richard.hightower@pgnmail.com Cc: Quichocho, Jessie; Jackson, Christopher; Hardgrove, Matthew; Grover, Ravinder

Subject:

H. B. Robinson Steam Electric Plant Unit No. 2 - Acceptance Review of License Amendment Request to Modify TS 3.4.12, Low Temperature Overpressure Protection System (TAC No. MF2718) 1

By letter dated September 10, 2013 (ADAMS Accession No. ML13262A008), Duke Energy submitted a license amendment request (LAR) for H. B. Robinson Steam Electric Plant (HBREP), Unit No. 2. The proposed LAR would modify Technical Specification (TS) Surveillance Requirement 3.4.12.6, of TS 3.4.12, Low Temperature Overpressure Pressure System, with a Note that does not require that the surveillance be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing the reactor coolant system cold leg temperature to less than or equal to 350 F, which is the temperature when LTOP operability controlled by TS 3.4.12 is credited. In addition, the FREQUENCY requirement is modified to simply 31 days. The purpose of this e-mail is to provide the results of the NRC staffs acceptance review of this LAR. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

The NRC staff has reviewed your application and concluded that it does provide technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed LAR in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review as compared to the detailed technical review, there may be instances in which issues that impact the NRC staffs ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. If additional information is needed, you will be advised by separate correspondence.

If you have any questions, please contact me.

Siva P. Lingam U.S. Nuclear Regulatory Commission Project Manager (NRR/DORL/LPL2-2)

Sequoyah Nuclear Plant St. Lucie Plant Robinson Steam Electric Plant Location: O8-D5; Mail Stop: O8-G9a Telephone: 301-415-1564; Fax: 301-415-1222 E-mail address: siva.lingam@nrc.gov 2

Hearing Identifier: NRR_PMDA Email Number: 1155 Mail Envelope Properties (Siva.Lingam@nrc.gov20140310071700)

Subject:

H. B. Robinson Steam Electric Plant Unit No. 2 - Requests for Additional Information (RAIs) for License Amendment Request to Modify TS 3.4.12, Low Temperature Overpressure Protection System (TAC No. MF2718)

Sent Date: 3/10/2014 7:17:38 AM Received Date: 3/10/2014 7:17:00 AM From: Lingam, Siva Created By: Siva.Lingam@nrc.gov Recipients:

"Quichocho, Jessie" <Jessie.Quichocho@nrc.gov>

Tracking Status: None "Jackson, Christopher" <Christopher.Jackson@nrc.gov>

Tracking Status: None "Hardgrove, Matthew" <Matthew.Hardgrove@nrc.gov>

Tracking Status: None "Parks, Benjamin" <Benjamin.Parks@nrc.gov>

Tracking Status: None "Grover, Ravinder" <Ravinder.Grover@nrc.gov>

Tracking Status: None "richard.hightower@pgnmail.com" <richard.hightower@pgnmail.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 5051 3/10/2014 7:17:00 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: