ML20093J098
| ML20093J098 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/21/2020 |
| From: | Andrew Hon NRC/NRR/DORL/LPL2-2 |
| To: | Kapopoulos E Duke Energy Progress |
| Wentzel, Michael | |
| References | |
| EPID L-2019-LLA-0170 | |
| Download: ML20093J098 (15) | |
Text
August 21, 2020 Mr. Ernest J. Kapopoulos, Jr.
Site Vice President H. B. Robinson Steam Electric Plant Duke Energy Progress, LLC 3581 West Entrance Road, RNPA01 Hartsville, SC 29550
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OF AMENDMENT NO. 269 REGARDING TECHNICAL SPECIFICATION CHANGE TO INCORPORATE THREE NEW FEEDWATER BYPASS ISOLATION VALVES (EPID NO. L-2019-LLA-0170)
Dear Mr. Kapopoulos:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 269 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2. This amendment is in response to your application dated July 29, 2019.
This amendment would modify Technical Specification (TS) 3.7.3, Main Feedwater Isolation Valves, Main Feedwater Regulation Valves, and Bypass Valves, to incorporate three new feedwater bypass isolation valves. This TS 3.7.3 change also revises the Completion Time for Required Action C.1 for an inoperable bypass valve to reflect the redundancy added to the configuration and to align with NUREG-1431, Standard Technical Specifications, Westinghouse Plants.
A copy of our related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.
Sincerely,
/RA/
Andrew Hon, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosures:
- 1. Amendment No. 269 to DPR-23
- 2. Safety Evaluation cc: Listserv
DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-261 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 269 Renewed License No. DPR-23
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Duke Energy Progress, LLC (the licensee),
dated July 29, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
Enclosure 1
- 2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment. Paragraph 3.B. of Renewed Facility Operating License No. DPR-23 is hereby amended to read as follows:
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 269 are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of its date of issuance and shall be implemented prior to startup from the fall 2020 refueling outage.
FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Undine S. Undine S. Shoop Date: 2020.08.21 Shoop 10:29:33 -04'00' Undine Shoop, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed License and Technical Specifications Date of Issuance: August 21, 2020
ATTACHMENT TO LICENSE AMENDMENT NO. 269 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace page 3 of Renewed Facility Operating License No. DPR-23 with the attached page 3.
Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Page Insert Page 3.7-8 3.7-8 3.7-9 3.7-9
D. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; E. Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.
- 3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
A. Maximum Power Level The licensee is authorized to operate the facility at a steady state reactor core power level not in excess of 2339 megawatts thermal.
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 269 are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
(1) For Surveillance Requirements (SRs) that are new in Amendment 176 to Final Operating License DPR-23, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 176. For SRs that existed prior to Amendment 176, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 176.
Renewed Facility Operating License No. DPR 23 Amendment No. 269
MFIVs, MFRVs, and Bypass Valves 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Main Feedwater Isolation Valves (MFIVs), Main Feedwater Regulation Valves (MFRVs), and Bypass Valves LCO 3.7.3 Three MFIVs, three MFRVs, and six bypass valves shall be OPERABLE.
APPLICABILITY: MODES 1, 2, and 3 except when MFIV, MFRV, or bypass valve is closed or isolated by a closed manual valve.
ACTIONS
NOTE-------------------------------------------------------------
Separate Condition entry is allowed for each valve.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more MFIVs A.1. Close or isolate MFIV. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable.
AND A.2. Verify MFIV is closed or Once per 7 days isolated.
B. One or more MFRVs B.1. Close or isolate MFRV. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable.
AND B.2. Verify MFRV is closed or Once per 7 days isolated.
(continued)
HBRSEP Unit No. 2 3.7-8 Amendment No. 269
MFIVs, MFRVs, and Bypass Valves 3.7.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. One or more inoperable C.1 Close or isolate bypass 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> bypass valves in different valve.
flow paths.
AND C.2 Verify bypass valve is Once per 7 days closed or isolated.
D Two valves in the same 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 /> flow path inoperable. path.
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 met. AND E.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the closure time of each MFRV and bypass In accordance with valve is within limits on an actual or simulated the INSERVICE actuation signal. TESTING PROGRAM SR 3.7.3.2 Verify the closure time of each MFIV is within limits on In accordance with an actual or simulated actuation signal. the INSERVICE TESTING PROGRAM HBRSEP Unit No. 2 3.7-9 Amendment No. 269
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 269 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DUKE ENERGY PROGRESS, LLC H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261
1.0 INTRODUCTION
By request dated July 29, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19210D020), as supplemented by the letter dated May 18,2020 (ADAMS Accession No. ML20139A231), Duke Energy Carolina (Duke Energy, the licensee) requested changes to the Technical Specifications (TS) for H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP).
This amendment would modify TS 3.7.3, Main Feedwater Isolation Valves (MFIVs), Main Feedwater Regulation Valves (MFRVs), and Bypass Valves, to incorporate three new feedwater bypass isolation valves (new BV). This TS 3.7.3 change also revises the Completion Time for Required Action C.1 for an inoperable bypass valve to reflect the redundancy added to the configuration and to align with NUREG-1431, Standard Technical Specifications, Westinghouse Plants.
Each steam generator's feedwater flow path currently has one MFRV, one MFIV and one existing bypass valve (existing BV). The proposed change is associated with the resolution of a legacy plant design issue related to the main steam line break (MSLB) analysis. As stated in the request, the Updated Final Safety Analysis Report (UFSAR) for the containment analysis and design basis event response assumed the capability to withstand the most limiting single active failure but did not consider failure of feedwater bypass valves. To resolve the single failure vulnerability, the Licensee is installing a new BV in each of the three feedwater bypass lines under Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments. The licensees request and the U.S. Nuclear Regulatory Commission (NRC) staffs evaluation addressed the TS changes related to new BVs.
The supplement provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on December 3, 2019 (84 FR 66227).
2.0 REGULATORY EVALUATION
2.1 System Description HBRSEP is equipped with three steam generators (SG). Feedwater is independently supplied to each SG through a MFIV, followed in series by a MFRV. In addition to these main feedwater valves, each line contains a bypass line with a smaller regulating valve that bypasses both the MFIVs and MFRVs and is connected upstream of the MFIVs. The bypass valves are normally closed during full power operation, will automatically close on an engineered safety features (ESF) signal (i.e., safety injection signal or feedwater isolation signal), and are used primarily during startup and shutdown when reduced feedwater flow is required to maintain SG water inventory. The bypass valves may also be used during full power operation when automatic control of the MFRVs is not available. Each SG's feedwater flow path currently has one MFRV, one MFIV and one existing BV. Because the bypass line is connected upstream of the MFIVs and bypass both MFRV and MFIV, there is no redundancy for bypass line isolation.
The safety function of the bypass valves is to provide isolation of feedwater flow to the secondary side of the steam generators following a high energy line break. Closure of the MFIVs, MFRVs and existing BV on an ESF signal terminates main feedwater flow to the steam generators, limiting the consequences of a main steam line break. With the current configuration, the isolation capability for the bypass line consists of a single existing BV per bypass flow path with no backup valve. Installation of a second valve in each bypass flow path would add redundancy to the configuration such that with one inoperable valve a second operable valve would be available to provide the automatic isolation function.
2.2 Description of the Proposed Changes The proposed changes would revise TS 3.7.3, Main Feedwater Isolation Valves (MFIVs), Main Feedwater Regulation Valves (MFRVs), and Bypass Valves, to include the three new BVs, resulting in a total of six bypass isolation valves within the scope of the TS. The license amendment request (LAR) also proposed extending the Completion Time for TS 3.7.3, Condition C, for an inoperable bypass valve from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The configuration of the bypass line and the crediting of the non-safety related new BV as a backup to the safety related existing BVs will resolve the current lack of suitable redundancy.
As such, the licensee proposed the new BVs for inclusion within the scope of TS 3.7.3 because the valves satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) as part of the primary success path to mitigate a main steam line break accident.
The licensee proposed the following TS changes:
2.2.1 Proposed Change to TS LCO 3.7.3 Currently, LCO 3.7.3 requires three MFIVs, three MFRVs, and three bypass valves to be OPERABLE. Each SG's feedwater flow path currently has one MFRV, one MFIV and one existing BV. The proposed revision would require six bypass valves (2 per steam generator) to be OPERABLE, in addition to the existing three MFIVs and three MFRVs required by the LCO.
The TS change is associated with a physical modification the licensee stated would be implemented under the provisions of 10 CFR 50.59, to replace the existing manual valve in each of the three bypass lines with new air-operated valves. The new air-operated valves would automatically close on an ESF signal and would fail closed on a loss of air pressure.
2.2.2 Proposed Change to TS 3.7.3.C Condition and Completion Time Currently, Condition C applies with one or more BVs inoperable, and requires action to close or isolate the BV within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and verify the BV is closed or isolated once per 7 days. If more than one valve is inoperable, more than one flow path is currently affected because there is only one automatic existing BV in each bypass flow path. The licensee proposed revising Condition C to apply when one or more BVs in different flow paths are inoperable to differentiate from the condition when two BVs in the same flow path are inoperable. Thus, the current wording, "One or more bypass valves inoperable" would be changed to "One or more inoperable bypass valves in different flow paths." The Licensee indicated this change will help ensure the proper application of Condition C and its associated Required Action and Completion Time because existing Condition D applies with two inoperable valves in the same flow path.
Additionally, the licensee proposed a revision to the Completion Time associated with TS 3.7.3, Required Action C.1 to close or isolate the BV, from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, which reflects the redundancy added to the BV configuration and adopts the Completion Time provided in NUREG-1431.
2.3 Regulatory Requirements and Guidance Used in the Evaluation of the Changes The regulation at 10 CFR 50.36, Technical Specifications, provides the regulatory requirements for TS.
The regulation 10 CFR 50.36(b) requires TS to be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto.
The regulation at 10 CFR 50.36(c)(2)(i) states that TS will include limiting conditions for operation (LCO) which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. This paragraph additionally states that when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
The regulation at 10 CFR 50.36(c)(2)(ii) states that a TS LCO of a nuclear reactor must be established for each item meeting one or more of four listed criteria. Criterion 3 is A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The NRCs guidance for the format and content of licensee TS can be found in NUREG-1431, Standard Technical Specifications, Westinghouse Plants NUREG-0138, "[NRC] Staff Discussion on Fifteen Technical Issues Listed in Attachment to November 3, 1976 Memorandum From Director, Office of Nuclear Reactor Regulation (NRR) to NRC Staff" contains a discussion on reliance of non-safety components in the steam and feedwater systems and loss of equipment not designed to withstand a safe shutdown earthquake (SSE) coincident with an assumed steam line break accident.
3.0 TECHNICAL EVALUATION
The licensee has proposed to add three new air operated bypass valves and include these within the scope of TS 3.7.3. Currently, each steam generator's feedwater flow path has one MFRV, one MFIV and one existing BV. Thus, the LCO will be revised to include six bypass valves following modifications, instead of the three existing bypass valves. The licensee is proposing to add the additional new BV (non-safety) to provide redundancy to the existing BV (safety related) for each bypass line.
The existing BVs (FCV-479, 489 & 499) are 4-inch, safety grade, Quality Class A, seismically qualified air-operated globe valves that fail-closed on a loss of air and receive an ESF signal to close. These existing BVs are currently included, along with the MFRVs and MFIVs, within the scope of TS 3.7.3.
The new BVs (FW-9A, B & C) are 4-inch, non-safety grade, Quality Class B, seismically mounted (not seismically qualified), air-operated valves that fail-closed on a loss of air and receive an ESF signal to close. These new BVs will provide a backup isolation function to the existing BVs, as described above.
The MFRVs and existing bypass valves in the feedwater line to each SG maintain the proper water level in the SGs for all load conditions. As described in UFSAR 10.4.6, the bypass valves are used at low power levels to prevent erosion damage to the MFRVs and for finer feedwater flow control. At higher power levels, the MFRVs are in operation while the BVs are shut.
The safety function of the bypass valves is to provide isolation of feedwater flow to the secondary side of the SGs following a high energy line break. An active failure of the existing bypass valve, whereby the valve fails to close, would increase the secondary mass available for release to the containment structure. This can result in a higher peak containment pressure that could challenge the containment design pressure.
While the new BVs are not safety-grade equipment, they are provided as backup in the unlikely event a failure prevents the safety related existing BV from fully closing. The safety related existing BVs close on receipt of a safety injection signal or a feedwater isolation signal and credit is taken in the containment accident analyses for these valves to close on demand.
These new BVs will also close on receipt of the same ESF signals as existing BVs. As required in SR 3.7.3.1, the new BVs will be included in the Inservice Testing Program and will be tested to the same standards (frequency and closure time) as the existing BVs. Therefore, surveillance testing of the non-safety new BVs will be required consistent with existing safety related BVs. Inclusion of the new BVs within the scope of TS 3.7.3 subjects them to the same TS LCO and Surveillance Requirements as the existing BVs and allows them to be credited as backups to the existing BVs because they would satisfy the performance criteria established by the main steam line break accident analysis.
One difference between existing BV (seismic qualified) and new BV (not seismic qualified) is lack of seismic qualification. However, coincident occurrence of two infrequent, independent events, such as earthquakes and an unrelated piping failure within containment, is not credible.
The events are independent because main steam system piping inside containment is designed to withstand the SSE without loss of function. This is further supported by NUREG-0138, Issue No. 1, Treatment of Non-Safety Grade Equipment in Evaluations of Postulated Steam Line Break Accidents. This NUREG states that loss of equipment not designed to withstand an SSE is not assumed coincident with an assumed spontaneous steam line break accident and
discusses the acceptability of reliance on non-safety related components for feedwater isolation as a backup to a single failure in safety related components. Thus, the staff found reliance on equipment that is not safety-related to be acceptable as a backup to safety-related equipment for mitigation of PWR secondary system ruptures based on the low frequency of this event and the reduced consequences relative to a reactor coolant system rupture.
As indicated above, the bypass valves are normally closed during full power operation, will automatically close on an ESF signal, and are used primarily during startup and shutdown when reduced feedwater flow is required to maintain SG water inventory. Therefore, the bypass feedwater flowpath is required a limited amount of time and automatic closure is important only for infrequent events during this limited time.
3.1 Proposed Change to TS 3.7.3 Condition C Currently, Condition C "One or more bypass valves inoperable" requires action to close or isolate the bypass line if one or more valves are inoperable within the Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, since the current configuration contains only one bypass valve per flow path. The requirements associated with Condition C are thus based on a single inoperable bypass valve in any given flow path. Condition C also applies when more than one bypass valve is inoperable in different flow paths in the current configuration.
The proposed revision to Condition C is to apply when one or more bypass valves in different flow paths are inoperable. The current wording of the condition, "One or more bypass valves inoperable" is proposed to read One or more inoperable bypass valves in different flow paths.
Since current TS requirements apply to more than one inoperable valve in different flow paths, the new condition similarly applies to inoperable valves in different flow paths. While similar, this new condition is more conservative than current requirements, due to added redundancy.
Each bypass feedwater flow path can be considered independently because isolation of each flow path mitigates only a postulated main steam line break accident associated with the single SG receiving feedwater from that path. The staff finds the revised wording acceptable since the change results in conditions consistent with the current Condition C in which action is entered when the single bypass valve that provides automatic isolation becomes inoperable in one or more flow paths. For two inoperable bypass valves in the same flow path, Condition D applies.
Condition D Two valves in the same flow path inoperable is representative of both redundant bypass valves on the same line being inoperable, which is consistent with the current valve configuration with loss of one bypass valve.
3.2 Proposed Change Completion Time for TS 3.7.3 Required Action C.1 Currently, Condition C requires action to close or isolate an existing BV if one or more are inoperable with a Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The proposed revision of Completion Time associated with TS 3.7.3, Required Action C.1, is to change from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to reflect the redundancy added to the configuration and to adopt the Completion Time provided in Westinghouse Standard Technical Specifications, (Revision 4) to allow time for maintenance and repairs.
The proposed revision to TS 3.7.3 is adopted from NUREG-1431. The TS BASES discussion in NUREG-1431 describes a 72-hour Completion Time related to the feedwater regulator bypass valves. The STS indicates,
With one associated bypass valve in one or more flow paths inoperable, action must be taken to restore the affected valves to OPERABLE status, or to close or isolate inoperable affected valves within [72] hours. When these valves are closed or isolated, they are performing their required safety function.
The [72] hour Completion Time takes into account the redundancy afforded by the remaining OPERABLE valves and the low probability of an event occurring during this time period that would require isolation of the MFW flow paths. The [72] hour Completion Time is reasonable, based on operating experience.
The current 8-hour Completion Time is based on a single isolation valve configuration in the bypass line and no additional isolation valve to address an inoperable bypass valve. Installation of a second new BV per flow path adds redundancy to the configuration such that, even with one inoperable bypass valve in a flow path, a second operable bypass valve could be available to provide the automatic isolation function.
Criterion 3 of 10 CFR 50.36(c)(2)(ii) states that an LCO must be established for components that are part of the primary success path and which function or actuate to mitigate a design basis event that presents a challenge to a fission product barrier. Since the licensee has credited the new BVs as the single failure backup to the safety related existing BV FCV-479, 489 & 499, the new BVs satisfy Criterion 3. The staff determined that the TS, as amended by the proposed changes, will continue to meet the requirements of 10 CFR 50.36(c)(2)(ii) because the new BVs will be included within the scope of the TS 3.7.3 LCO. The staff finds the addition of the new BVs to the TS requirements results in added safety and it is therefore acceptable for the new requirements to be included in TS 3.7.3.
10 CFR 50.36(b) requires TS to be derived from the analyses and evaluation included in the safety analysis report and amendments thereto. The staff has determined that the TS, as amended by the proposed changes, will continue to meet the requirements of 10 CFR 50.36(b) because the changes to Condition C are based on the licensees evaluation provided in the LAR and are acceptable.
10 CFR 50.36(c)(2)(i) states that when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. Considering the added redundancy with newly added valves, consistency with STS and the low probability of an event occurring during the time period that would require isolation of the feedwater flow paths, the staff finds the limited increase of the Completion Time to close or isolate bypass valves is reasonable. Therefore, the staff has determined that the TS, as amended, will meet the requirements of 10 CFR 50.36(c)(2)(i) because they will contain acceptable remedial actions the licensee must follow while the LCO is not met.
3.3 Technical Evaluation Conclusion
Based on above, the NRC staff concludes that the proposed changes which (1) modify TS 3.7.3, to incorporate three new feedwater bypass isolation valves and (2) revise the Completion Time for Required Action C.1 for an inoperable bypass valve to reflect the redundancy added to the configuration and align with NUREG-1431 STS, are acceptable and that the TS will meet the requirements in 10 CFR 50.36.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the State of South Carolina official was notified of the proposed issuance of the amendment on April 17, 2020. The State official did not provide any comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20. The NRC 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 the amendment involves no significant hazards consideration, published in the Federal Register on December 3, 2019 (84 FR 66227), and there has been no public comment on such finding. Accordingly, the 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 the amendment.
6.0 CONCLUSION
The Commission 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) there is reasonable assurance that such activities will be conducted in compliance with the Commissions 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.
Principle Contributor: Gordon Curran Date: August 21, 2020
E. Kapopoulos
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OF AMENDMENT NO. 269 REGARDING TECHNICAL SPECIFICATION CHANGE INCORPORATE THREE NEW FEEDWATER BYPASS ISOLATION VALVES (EPID NO. L-2019-LLA-0170) DATED AUGUST 21, 2020 DISTRIBUTION:
PUBLIC RidsACRS_MailCTR Resource RidsRgn2MailCenter Resource RidsNrrDorlLpl2-2 Resource RidsNrrPMRobinson Resource RidsNrrLABAbeywickrama Resource RidsNrrDssStsb Resource RidsNrrDssCspb Resource GCurran, NRR MHamm, NRR ADAMS Accession No.: ML20093J098 *by e-mail OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA* NRR/DE/SCPB/BC* NRR/DSS/STSB/BC*
NAME AHon BAbeywickrama BWittick VCusumano DATE 04/02/2020 04/14/2020 03/20/2020 04/10/2020 OFFICE OGC - NLO* NRR/DORL/LPL2-2/BC* NRR/DORL/LPL2-2/PM*
NAME STurk UShoop AHon DATE 04/21/2020 08/21/2020 08/21/2020 OFFICIAL RECORD ONLY