ML14183A024
| ML14183A024 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/12/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML14183A023 | List: |
| References | |
| GL-82-16, NUDOCS 8510040089 | |
| Download: ML14183A024 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.95 TO FACILITY OPERATING LICENSE NO. DPR-23 CAROLINA POWER AND LIGHT COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I. Introduction Generic Letter (GL) 82-16 contained guidance on certain NUREG-0737 items and acceptance criteria for associated Technical Specificaitons (TS). The licensee's submittal and the Technical Specifications for Robinson Unit No. 2. were reviewed. Technical assistance to Region II was provided under contract with EG&G. The contractor's Technical Evaluation Report (TER)
No. EGG-EA-6437 documents their evaluation.
We have reviewed the contractor's TER and agree with the conclusion that there are seven items that apparently do not conform to the guidance contained in GL 82-16. Five of these have been reviewed as separate issues.
The remaining two are: (1) Overtime Limits relying on Administrative Controls instead of specific Technical Specifications; and (2)
Anticipatory Trip on T.T - failure to include the Turbine Trip in the protection system setting. This Safety Evaluation is concerned with the resolution of the seven open items contained in the EG&G TER No. EGG-EA-6437, Section 4 Conclusions.
II. Evaluation The enclosed report (EEG-EA-6437) was prepared for us by EG&G Idaho, Inc.
as part of our technical assistance contract program. Their report provides their technical evaluation of the compliance of the Licensee's submittal with NRC-provided criteria. Despite these "informal" notation, this is the final report of the contractor on this matter. This staff has reviewed this TER and agrees with the evaluation.
Based on the EG&G TER the licensee conforms to all issues addressed in Generic Letter 82-16 with the exception of the items listed and resolved in this evaluation (See Conclusions in the TER). Resolution of the seven unresolved items are as follows:
- 1. Section 3.1 STA Training I.A.1.1.3.--Until further guidance is provided by the Commission, no further licensing action can be taken to determine whether the exact training program for the STA is required to be in the TS.
6510040069 850912 PDR ADOCK 002 P
-2 The staff concluded that the licensee's STA program is acceptable by letter dated January 15, 1982. Future Commission guidance concerning the STA training requirements, retraining and replacement will be handled as a plant specific issue, therefore, we consider this item closed.
- 2. Section 3.2 Shift Manning-Overtime Limits--The CP&L policy is contained in administrative procedures rather than in the TS and, as stated in their response, the CP&L policy deviates from the NRR criteria.
By letter dated May 15, 1985 the licensee requested a revision to Technical Specification 6.2.3; Facility Staff. The revision adds staff overtime limitations that the licensee previously had implemented by administrative procedures. The licensee's overtime policy was previously approved by NRC letter dated November 15, 1981. Subsequent to the November 5, 1981 approval, we required the licensee to incorporate their overtime limit policy into Technical Specifications. By letter dated May 15, 1985 the licensee requested the addition of the previously approval overtime policy into their TS. We conclude that the proposed changes are acceptable and therefore consider this item closed.
- 3. Section 3.4 Safety Grade AFW System Initiation and Flow Indication (II.E.1.2)--The NRC is presently reviewing open items of the original Safety Evaluation pertaining to safety grade flow indication and initiation as a separate evaluation.
By NRC letter dated June 20, 1984, we approved the licensee's submittals concerning II.E.1.1 and II.E.1.2 open items with one exception. The only remaining concern was automatic bus transfer (ABT). This item is currently under staff review as a separate issue, TAC No. 55156, ABT for AFW initiation/flow. Therefore, we consider NUREG-0737 Item II.E.1.2. closed.
- 4. Section 3.6 Containment Pressure Setpoint II.E.4.2.5.--The licensee has submitted a TS change request to correct the containment pressure setpoint. This request is presently under review by the NRC.
By letter dated January 11, 1983 the licensee submitted a request to revise the containment pressure setpoints contained in their Technical Specification. The request was reviewed by the staff and approved by letter dated April 4, 1984 which issued Amendment No. 79. Therefore, we consider this item closed.
- 5. Section 3.7 Containment Purge Valves (II.E.4.2.6)--The TS for H. B. Robinson Unit 2 do not comply with Generic Letter 82-16 for this item.
The requirement for this item is that for containment purge valves that do not satisfy the operability requirements...
the valves must be sealed closed...
and must be verified closed at least every 31 days. GL 82-16 requires technical specifications to assure that the valves are sealed closed and verified. By letter dated December 5, 1983 the staff approved
-3 these valves as operable valves for the H. B. Robinson Unit 2 Plant.
Therefore, technical specifications are not required for the Item II.E.4.2.6. non-operable valve criterion and we consider this item closed.
- 6. Section 3.8 Radiation Signal on Purge Valves (II.E.4.2.7.)
The TS for H. B. Robinson Unit 2 do not comply with Generic Letter 82-16 for this item. A licensee submittal for this is presently under NRC review and licensing action may be required, following this review.
The staff review for this item was completed during our review of the Radiological Effluent Technical Specifications (RETS). The approval was by letter dated October 4, 1984 which issued Amendment No. 85. Therefore, we consider this item closed.
- 7. Section 3.12 Reporting Safety Valve and Relief Valve Failures and Challenges (II.K.3.3)--The TS for H. B. Robinson Unit 2 do not comply with Generic Letter 82-16 for this item.
The licensee stated that challenges to the pressurizer PORV's and safety valves are included in the HBR-2 annual report and, therefore, including the reporting requirements in Technical Specifications (TS) was redundant and unnecessary. This position did not meet the NUREG-0737 item II.K.3.3 position. By letter dated May 15, 1985 the licensee submitted a request for TS change to add reporting of challenges to the safety and relief valves. GL 82-16 model TS for this item also required a Prompt Notification (PN) for failure of either valve. Subsequent to this requirement Title 10 of the Code of Federal Regulations published requirements for prompt (immediate) notification in Part 50.72; therefore, TS for these failures are no longer required. Based on our review of the licensee's submittal as discussed above we find the requested TS change acceptable and consider this item closed.
- 8. Section 3.13 Anticipatory Trips on Turbine Trips (II.K.3.12)-
The TS for H. B. Robinson Unit 2 do not comply with Generic Letter 82-16 for this item.
The licensee has anticipatory trip on turbine trip. Their TS contain LCO's for the turbine trip and surveillance testing. The turbine trip signal setpoints are not incorporated in the Technical Specifications. The licensee's basis for not including the setpoints in their TS is because credit is not taken for these in the transient and accident analysis.
Since the transient and accident analysis has demonstrated that the plant is acceptably safe without taking credit for the turbine trip setpoints and since the licensee has in-place TS for LCO's and surveillance testing requirements for the turbine trip we find the licensee's current Technical Specification acceptable. However, should the licensee take credit for the turbine trip setpoints in future Chapter 15 events (transient and accident analysis), the licensee will be required to submit technical specifications incorporating these setpoints. Based on the enclosed TER and the above discussion we find this item acceptable and consider this item closed.
-4 III. Summary The staff and its contractor have reviewed all GL 82-16 issues and the licensee's resolution for the issues and find them acceptable. Therefore, we consider the NUREG-0737 issues contained in GL 82-16 closed.
IV. Environmental Consideration This amendment involves a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The 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 this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR Sec 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 this amendment.
V. Conclusion We have 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, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Dated: September 12, 1985 Principal Contributors:
R. C. Lewis, RII G. Requa