ML14188B015

Request for Technical Specifications (TS) Change Regarding Correction to TS 5.5.9.b.2, Steam Generator (SG) Program Accident-Induced Leakage Performance Criterion

ML14188B015
Person / Time
Site:	Robinson
Issue date:	06/20/2014
From:	William Gideon Duke Energy Carolinas, Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RAI/14-0053
Download: ML14188B015 (11)

Text

W R. GIDEON H. B. Robinson Steam Electric Plant Unit 2 Site Vice President ENERGY Duke Energy 3581 West Entrance Road Hartsville, SC 29550 10 CFR 50.90 Serial: RNP-RAI14-0053 JUN 2 0 2014 ATTN: Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 Request for Technical Specifications (TS) Change Regarding Correction to TS 5.5.9.b.2, Steam Generator (SG) Program Accident-Induced Leakage Performance Criterion Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Duke Energy Progress, Inc. is submitting a request for an amendment to the Technical Specifications (TS) for H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). The proposed amendment would correct the accident-induced leakage performance criterion for the Steam Generator Program stated in TS 5.5.9.b.2. Duke Energy Progress, Inc, has concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

The Enclosure provides an evaluation of the proposed change. Proposed TS markups and retyped page are included as attachments to the Enclosure. There are no regulatory commitments made in this submittal. Approval of the proposed license amendment is requested by May 15, 2015 with the amendment being implemented within 120 days of issuance.

In accordance with 10 CFR 50.91, a copy of this application is being provided to the State of South Carolina.

If you have any questions regarding this submittal, please contact Mr. R. Hightower at (843) 857-1329.

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

Executed On:_________

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United States Nuclear Regulatory Commission Serial: RNP-RA/14-0053 Page 2 of 2 WRG/jmw

Enclosure:

Evaluation of the Proposed Change cc: Mr. V. M. McCree, NRC, Region II Ms. Martha C. Barillas, NRC Project Manager, NRR NRC Resident Inspector, HBRSEP, Unit No. 2 Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/14-0053 Page 1 of 9 ENCLOSURE Evaluation of the Proposed Change

Subject:

Request for Technical Specification Change Regarding Correction to TS 5.5.9.b.2, Steam Generator (SG) Program Accident-Induced Leakage Performance Criterion

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination 4.3 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. Technical Specification Page Markups

2. Retyped Technical Specification Page

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/1 4-0053 Page 2 of 9 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Appendix A to Renewed Operating License No.

DPR-23 for H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). The proposed change to Technical Specification (TS) 5.5.9.b.2 would correct the accident-induced leakage rate for any design basis accident other than a steam generator tube rupture. The accident-induced leakage rate value provided in TS 5.5.9.b.2 was incorrectly specified as 75 gallons per day (gpd) per steam generator and is being corrected to 150 gpd per steam generator. Approval of the proposed license amendment is requested by May 15, 2015, with the amendment being implemented within 120 days of issuance.

2.0 DETAILED DESCRIPTION The proposed change to Technical Specification (TS) 5.5.9.b.2 would correct an editorial error in the accident-induced leakage rate value for any design basis accident other than a steam generator (SG) tube rupture. During the HBRSEP2 licensing submittal of Technical Specifications Task Force (TSTF) 449, Revision 4, Steam Generator Tube Integrity, the accident-induced leakage rate value located in TS 5.5.9.b.2 was incorrectly specified as the operational leakage performance criterion (75 gpd per SG), which is indicated by reference to limiting condition for operation (LCO) 3.4.13, "RCS OperationalLEAKAGE," in TS 5.5.9.b.3. TS 5.5.9.b.2 is being corrected to specify the accident-induced leakage performance criterion value of 150 gpd per SG.

NRC Generic Letter (GL) 2006-01, Steam GeneratorTube Integrity and Associated Technical Specifications,conveyed the NRC's concern that current TS requirements may not be sufficient to ensure that SG tube integrity can be maintained in accordance with current licensing and design basis. GL 2006-01 requested that addressees either submit a description of their program for ensuring SG tube integrity for the interval between inspections or adopt alternative requirements for ensuring SG tube integrity. HBRSEP2 elected to adopt TSTF traveler 449, Rev. 4, which adequately addresses the NRC staff's concerns with the existing TS.

On May 30, 2006, HBRSEP2 submitted a license amendment request (ADAMS Accession No. ML061520207) in accordance with the NRC-approved TSTF-449 model application. The scope of this application includes, among other things, changes to the primary-to-secondary leakage requirements proposed by the TSTF as well as a HBRSEP2-specific change to the operational leakage performance criterion from 150 gpd to 75 gpd. This change was determined to be necessary to ensure there was sufficient (factor of 2) margin between the operational leakage limit and the accident-induced leakage limit, since such a margin between these limits was introduced in TSTF-449.

The model application for TSTF-449, Rev. 4 contains an insert (Insert 5.5.9) that replaced HBRSEP2 TS 5.5.9, including TS 5.5.9.b.2, the last sentence of which states, "Leakage is not to exceed [lgpm] per SG." As with numerous other plant-specific values referenced in the application, the leak rate value required here is plant specific and is to be entered by the applicant in the space provided between the brackets. HBRSEP2 inadvertently entered the incorrect value of 75 gpd for the accident-induced leakage rate in this sentence. The correct value for the accident-induced leakage rate in this sentence is 150 gpd. The accident-induced

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/14-0053 Page 3 of 9 leakage rate value is correctly specified throughout the remainder of the TSTF-449 submittal and no other corrections are requested.

3.0 TECHNICAL EVALUATION

The requested change to TS 5.5.9.b.2 corrects an editorial error in the specified accident induced leakage performance criterion value. The technical basis for the requested change is established in the dose consequence analysis performed for Engineering Change (EC) 47161, Alternate Source Term Dose Analysis. The calculations utilized the primary-to-secondary leakage value of 150 gpd per SG. This dose consequence analysis was incorporated into the HBRSEP2 licensing design basis via this EC. The HBRSEP2 UFSAR accident analysis (Chapter 15) was updated per Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, following the approval of the aforementioned dose consequence analysis by the Nuclear Regulatory Commission.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed TS change is a correction to an editorial error in TS 5.5.9.b.2 and does not adversely affect how the Steam Generator (SG) Program meets the associated regulatory requirements. The associated regulatory requirements include TS 3.4.13.d, RCS Operational LEAKAGE, which states the RCS operational LEAKAGE shall be limited to 75 gpd through any one SG, and TS 5.5.9.b.2 provides the accident-induced leakage performance criterion (erroneously stated as 75 gpd per SG).

4.2 No Significant Hazards Consideration Determination Duke Energy Progress, Inc. is proposing a change to Appendix A, Technical Specifications, of Facility Operating Renewed License No. DPR-23, for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). The proposed change to TS 5.5.9.b.2 is a correction to an editorial error in the specified accident-induced leakage performance criterion.

Duke Energy Progress, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/14-0053 Page 4 of 9 The proposed change is a correction to an editorial error in the specified accident induced leakage performance criterion of TS 5.5.9.b.2. The error in TS 5.5.9.b.2 being addressed by this proposed change was introduced at the time of the HBRSEP2 submittal of the NRC-approved Technical Specification Task Force (TSTF) traveler 449, Rev. 4, Steam GeneratorTube Integrity. The accident-induced leakage performance criterion will continue to be within the limit assumed in the accident analysis. As a result, neither the probability nor the consequences of any accident previously evaluated will be affected.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

No new or different accidents result from the proposed changes. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements or eliminate any existing requirements. The changes do not alter assumptions made in the safety analysis, it only corrects an editorial error in the accident-induced leakage performance criterion specified in the SG Program. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

This change will have no effect on the margin of safety. This proposed change corrects an editorial error in the accident-induced leakage performance criterion specified in the SG Program.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/14-0053 Page 5 of 9 Based on the above, Duke Energy Progress, Inc. concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusions In conclusion, based on the considerations discussed above, (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.

5.0 Environmental Consideration 10 CFR 51.22(c)(9) provides criteria for identification of licensing and regulatory actions for categorical exclusion from performing an environmental assessment. A proposed change for an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed change would not (1) involve a significant hazards consideration; (2) result in a significant change in the types of significant change in the types or significant increases in the amounts of any effluents that may be released offsite; (3) result in a significant increase in individual or cumulative occupational radiation exposure. Duke Energy Progress, Inc. has reviewed this request and determined the proposed change 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 needs to be prepared in connection with the issuance of the amendment.

6.0 References

1. TSTF-449, Revision 4, Steam GeneratorTube Integrity

2. HBRSEP2 UFSAR Section 15.6.3.2.3, Dose Analysis Assumptions

3. HBRSEP2 Engineering Change (EC) 47161 R3, Alternate Source Term Dose Analysis

4. HBRSEP2 Renewed Operating License, DPR-23, Appendix A, Technical Specifications Section 5.5.9, Steam Generator(SG) Program.

5. HBRSEP2 License Amendment Request Submittal dated 5/30/2006, ADAMS Accession No. ML061520207

U. S. Nuclear Regulatory Commission Attachment I to Enclosure to Serial RNP-RAI14-0053 Page 1 of 2 H. B. Robinson Steam Electric Plant, Unit No. 2 Request for Technical Specifications (TS) Change Regarding Correction to TS 5.5.9.b.2, Steam Generator (SG) Program Accident-Induced Leakage Performance Criterion MARKUP OF TECHNICAL SPECIFICATIONS PAGE

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.9 Steam Generator (SG) Proqram A Steam Generator Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the Steam Generator Program shall include the following:

a. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found" condition refers to the condition of the tubing during an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes.

Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged to confirm that the performance criteria are being met.

b. Performance criteria for SG tube integrity. SG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE.

1. Structural integrity performance criterion: All in-service steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cool down) and all anticipated transients included in the design specification, and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG. Leakage is not to exceed -

gallons per day per SG.

3. The operational LEAKAGE performance criterion is specified in LCO 3.4.13, "RCS Operational LEAKAGE."

(continued)

HBRSEP 5.0-12 Amendment No.

U. S. Nuclear Regulatory Commission Attachment II to Enclosure to Serial RNP-RAI14-0053 Page 1 of 2 H. B. Robinson Steam Electric Plant, Unit No. 2 Request for Technical Specifications (TS) Change Regarding Correction to TS 5.5.9.b.2, Steam Generator (SG) Program Accident-Induced Leakage Performance Criterion RETYPED TECHNICAL SPECIFICATIONS PAGE

• Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.9 Steam Generator (SG) Program A Steam Generator Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the Steam Generator Program shall include the following:

a. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found" condition refers to the condition of the tubing during an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes.

Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged to confirm that the performance criteria are being met.

b. Performance criteria for SG tube integrity. SG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE.

1. Structural integrity performance criterion: All in-service steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cool down) and all anticipated transients included in the design specification, and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG. Leakage is not to exceed 150 gallons per day per SG.

3. The operational LEAKAGE performance criterion is specified in LCO 3.4.13, "RCS Operational LEAKAGE."

(continued)

HBRSEP 5.0-12 Amendment No.