ML14183A165

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Safety Evaluation Supporting Amend 127 to License DPR-23
ML14183A165
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 06/21/1990
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML14183A164 List:
References
NUDOCS 9006260071
Download: ML14183A165 (4)


Text

61 ptREG4.

o UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.127 TO 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 May 25, 1990, the Carolina Power & Light Company submitted a request for changes to the H. B. Robinson Steam Electric Plant, Unit No. 2, (HBR-2) Technical Specifications (TS) to clarify that testing of the source range channel shall only be required prior to startup if not performed within the previous seven days.

The proposed amendment would change Table 4.1-1, "Minimum Frequencies for Checks, Calibrations and Test of Instrument Channels," by adding a note to Item 27, "Logic Channel Testing." The note applies to the testing frequency of the nuclear source range instrumentation so it will be consistent with Item 3, "Nuclear Source Range". The proposed amendment will also correct a typographical error and renumber a subsequent note on Table 4.1-1.

2.0 DISCUSSION AND EVALUATION This amendment is required because Item 27 of Table 4.1-1 of the TS requires monthly testing of the trip logic but does not currently provide for an exception for the source range channel. The licensee states that the source range logic has not been tested at power since the plant was licensed. A review of the TS and the plant specific hardware configura tion indicates that testing of the source range high flux trip is appropriate only prior to reactor startup. The plant equipment is such that testing of the source range trip logic while at power would result in damaging voltages to the source range detectors. To test at power would require the use of temporary jumpers to isolate the high voltage from the source range detectors. The use of jumpers is, in general, contrary to accepted practice. Item 3, "Nuclear Source Range," of Table 4.1-1 is specific in that the instrument channel testing is required only for startup and not on a monthly basis. Additionally, Table 3.5-2 states that when the intermediate range indicates a value greater than 1E-10 amps the source range minimum operable channel requirements do not apply.

906.260071 9100621 PDR ADOCK 0500026.1 F

PDC

The source range reactor trips are not included in the FSAR Chapter 15 transient and accident analysis but, as stated in Chapter 15, are used to provide protection during reactor startup only. It should also be noted that H. B. Robinson has separate source range instrumentation (in accordance with Regulatory Guide 1.97), which provides diverse source range information. The limitation of this test to times prior to start-up of the reactor would not lessen safety and is acceptable to the staff.

The licensee submittal included an additional change to correct an apparent typographical error for Item 27 and Item 30 of Table 4.1-1.

The staff agrees that the proposed changes are typographical in nature and are acceptable.

Based on the present equipment configurations and specific source range testing requirements addressed elsewhere in the TS, the proposed source range surveillance test interval (i.e., prior to each reactor startup if not performed within the last seven days) is acceptable to the staff. The proposed changes as referenced in the licensee's May 25 submittal are consistent with the source range testing requirements previously reviewed by the the staff, and are acceptable.

3.0 NEED FOR EXPEDITED ACTION On March 23, 1990, the licensee identified an inconsistency in the TS with respect to surveillance testing of the source range trip logic. The TS, as currently written, requires testing of the nuclear source range channels monthly, rather than prior to reactor startup if the test was not performed within the previous seven days. As stated in section 2.0, safe testing of the source range trip logic would require that the reactor be shutdown. Subsequent to the licensing event report (LER) submitted on April 2, 1990, a conference call was held between NRC staff and the licensee on May 16, 1990, during which the licensee decided to request an amendment to clarify the TS on this issue.

The source range logic surveillance test was last performed during a plant shutdown on May 19, 1990. According to the present TS, the next test should be performed by June 18, 1990. However, even with the allowed TS tolerance on surveillance interval periods, the next test is required by June 25, 1990. Therefore, exigent handling of the license amendment is needed to avoid shutting the facility down to test the nuclear source range instrument logic solely to meet the TS surveillance requirement.

4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards

-3 consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (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. The licensee has reviewed this request and determined:

1. 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 analyzed because previously evaluated accidents, as found in Chapter 15 of the UFSAR, do not discuss nor take credit for the source trip feature. Also, the proposed amendment does not introduce any new evolution or test, and cannot increase the probability or consequences of occurrence of any accident previously evaluated.
2. 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 accident previously evaluated. The proposed amendment is administrative and does not create any new tests, evolutions, or requirements. The amendment clarifies existing logic channel testing requirements and provides consistency with existing requirements for testing of nuclear source range channels. The source range instrument is deenergized during power operations, and no credit for the source range trip feature is taken in the UFSAR accident analysis. Therefore, this amendment will not create the possibility of a new kind of accident from any accident previously evaluated. The affected components will be available and will be verified operable prior to being required for service, consistent with the intent of the Technical Specification prior to the proposed amendment. Therefore, this amendment does not create the possibility of a different kind of accident from any accident previously evaluated.
3. Operation of the facility, in accordance with the proposed amendment, would not involve a significant reduction in a margin of safety. The source range channel testing requirements will be made consistent by this amendment.

These channels, including the logic channel portions, will be tested and verified operable prior to being required for service. The proposed amendment is administrative in nature and does not involve a safety-significant change to the Technical Specifications. Therefore, this amendment will not affect the margin of safety.

-4 Based on the review of the licensee's submittal, the staff has made a final determination that the licensee's amendment request does not involve a significant hazards consideration since operation of HBR-2 with the requested change would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (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.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change in a requirement in respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR part 20 and changes to the surveillance requirements. 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 off site, 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 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.

6.0 CONCLUSION

The Commission made a proposed determination that this amendment involves no significant hazards consideration, which was published in the FEDERAL REGISTER (55 FR 22975) on June 5, 1990, and consulted with the State of South Carolina. No public comments or requests for hearing were received, and the State of South Carolina did not have any comments.

The staff 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 this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

James Stewart Dated:

June 21, 1990