RNP-RA/06-0095, Request for Technical Specifications Change to Section 3.3.3, Post Accident Monitoring

Request for Technical Specifications Change to Section 3.3.3, Post Accident Monitoring

ML070360537
Person / Time
Site:	Robinson
Issue date:	02/02/2007
From:	Lucas J Progress Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/06-0095
Download: ML070360537 (15)

Text

10 CFR 50.90 Progress Energy Serial: RNP-RA/06-0095 FEB 0 2 2007 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE TO SECTION 3.3.3, POST ACCIDENT MONITORING Ladies and Gentlemen:

In accordance with the provisions of the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc., is submitting a request for an amendment to the Technical Specifications (TS) contained in Appendix A of the Operating License for H. B. Robinson Steam Electric Plant (HBRSEP),

Unit No. 2.

The proposed amendment will delete the TS requirements related to containment hydrogen monitors, as allowed by the revisions to 10 CFR 50.44, "Combustible gas control for nuclear power reactors," that became effective on October 16, 2003. The changes are consistent with Revision I of NRC-approved Technical Specifications Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 (68 FR 55416), as part of the Consolidated Line Item Improvement Process (CLIIP).

Attachment I provides an Affirmation as required by 10 CFR 50.30(b).

Attachment II provides a description of the current condition, a description and justification of the proposed changes, a No Significant Hazards Consideration Determination, and an Environmental Impact Consideration.

Attachment III provides a markup of the affected TS pages.

Attachment IV provides the retyped TS pages.

Progress Energy Carolinas, Inc.

Robinson Nuclear Plant 3581 West Entrance Road Hartsville, SC 29550

United States Nuclear Regulatory Commission Serial: RNP-RA/06-0095 Page 2 of 2 In accordance with 10 CFR 50.91(b), Progress Energy Carolinas, Inc., is providing the State of South Carolina with a copy of this license amendment request.

Nuclear Regulatory Commission approval of the proposed license amendment is requested by September 12, 2007, with an effective date of implementation within 60 days of issuance.

If you have any questions concerning this matter, please contact Mr. C. T. Baucom at (843) 857-1253.

Sincerely, J. F.tucas Manager - Support Services - Nuclear Attachments:

I. Affirmation II. Request for Technical Specifications Change to Section 3.3.3 III. Markup of Technical Specifications Pages IV. Retyped Technical Specifications Pages RAC/rac c: Mr. T, P. O'Kelley, Director, Bureau of Radiological Health (SC)

Mr. H. J. Porter, Director, Division of Radioactive Waste Management (SC)

Dr. W. D. Travers, NRC, Region II NRC Project Manager, NRR NRC Resident Inspector, HBRSEP Attorney General (SC)

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/06-0095 Page 1 of 1 AFFIRMATION The information contained in letter RNP-RA/06-0095 is true and correct to the best of my information, knowledge, and belief; and the sources of my information are officers, employees, contractors, and agents of Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. I declare under penalty of perjury that the foregoing is true and correct.

Executed On: Z 0 VT.eD. Walt Vice President, HBRSEP, Unit No. 2

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/06-0095 Page 1 of 4 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE TO SECTION 3.3.3 Description of Current Condition Technical Specifications (TS) Section 3.3.3, "Post Accident Monitoring," specifies requirements for containment hydrogen monitors in Table 3.3.3.1. Additionally, Condition E and the Note in Condition C apply to the hydrogen monitors. The edited pages in Attachment III show the current wording.

Description and Justification of the Proposed Changes This proposed change to the TS will delete the requirements for the hydrogen monitors.

Specifically, in TS Section 3.3.3, "Post Accident Monitoring," the hydrogen monitors will be deleted from Table 3.3.3-1. Additionally, Condition E and the Note in Condition C will be deleted, because these requirements are applicable to the hydrogen monitors.

The Nuclear Regulatory Commission (NRC) amended 10 CFR 50.44, "Combustible Gas Control in Containment," as described in Federal Register, Volume 68, No. 179, September 16, 2003, Final Rule, 10 CFR Parts 50 and 52, Combustible Gas Control in Containment, with an effective date of October 16, 2003. The amended rule eliminated the requirements for a hydrogen recombiner and relaxed the requirements for hydrogen monitoring. The elimination of the hydrogen recombiner from the H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, design and operating procedures has already been completed. The HBRSEP, Unit No. 2, TS did not include requirements related to the hydrogen recombiner. Therefore, a TS change was not necessary to eliminate the hydrogen recombiner requirements.

Additionally, the amended rule relaxes the requirements for containment hydrogen monitors. The revised rule allows the hydrogen monitors to be removed from the TS, to be downgraded from Category I to Category 3 for Regulatory Guide 1.97 compliance, and to be downgraded to non-safety-related. The NRC requires that containment hydrogen monitors continue to be maintained.

A generic Improved Standard TS (ISTS) change for the deletion of the hydrogen recombiner and hydrogen and oxygen monitors was prepared by the Technical Specifications Task Force (TSTF) and was approved by the NRC as TSTF-447, Revision 1, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors," on September 25, 2003 (68 FR 55416). This TSTF was also incorporated into the Consolidated Line Item Improvement Process (CLIIP). An example submittal and a generic NRC safety evaluation were prepared as part of the CLIIP.

The aspects of the TSTF/CLIIP that address the deletion of the hydrogen recombiner are not applicable to this specific change. Additionally, the sections of the TSTF/CLIIP related to containment oxygen monitors are not applicable for HBRSEP, Unit No. 2. However, the sections of the TSTF/CLIIP related to the deletion of hydrogen monitors from the TS are directly applicable to

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/06-0095 Page 2 of 4 this proposed change. The technical justification and safety evaluation presented in the TSTF/CLIIP related to hydrogen monitors are consistent with the HBRSEP, Unit No. 2, design and procedures and with this proposed TS change. The following excerpt is provided from the TSTF/CLIIP documentation:

"Hydrogen Monitoring Equipment: 50.44(b)(1) and the ISTS currently contain requirements for monitoring hydrogen. Licensees have also made commitments to design and qualification criteria for hydrogen monitors in NUREG-0737, Item II.F.1, Attachment 6 and RG 1.97. The hydrogen monitors are used to assess the degree of core damage and confirm that random or deliberate ignition has taken place and that containment integrity is not threatened by an explosive mixture. If an explosive mixture that could threaten containment integrity exists during a beyond design-basis accident, then other severe accident management strategies, such as purging and/or venting, would need to be considered. With the elimination of the design-basis LOCA hydrogen release, hydrogen monitors are no longer required to mitigate design-basis accidents and, therefore, the hydrogen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 Category 1, is intended for key variables that most directly indicate the accomplishment of a safety function for design-basis accident events. The hydrogen monitors no longer meet the definition of Category I in RG 1.97. As part of the rulemaking to revise 50.44 the Commission found that Category 3, as defined in RG 1.97, is an appropriate categorization for the hydrogen monitors because the monitors are required to diagnose the course of beyond design-basis accidents.

Hydrogen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary. Section 4 of Attachment 2 to SECY-00-0198 found that hydrogen monitoring was not risk-significant. Therefore, the rule making stated that the staff finds that hydrogen monitoring equipment requirements no longer meet the criteria of 50.36(c)(2)(ii) for retention in Technical Specifications and, therefore, may be removed from the Technical Specifications. The CLIIP for elimination of Post-Accident Sampling System requirements for Westinghouse and Combustion Engineering designs indicated that during the early phases of an accident, safety-grade hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration. The staff subsequently concluded that Category 3 hydrogen monitors also provide an adequate capability for monitoring containment hydrogen concentration during the early phases of an accident. Because the monitors are required to diagnose the course of beyond design basis accidents, each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing the course of beyond design-basis accidents."

As discussed in the Model Safety Evaluation published in the Federal Register on September 25, 2003 (68 FR 55416), Carolina Power and Light Company is making the following verifications and regulatory commitments:

A hydrogen monitoring system designed to the Category 3 criteria of Regulatory Guide 1.97 is installed at HBRSEP, Unit No. 2. In addition, a Carolina Power and Light Company regulatory commitment established as part of the removal of the Post Accident Sampling System from the TS included provisions for obtaining grab samples of the containment atmosphere that can be used to supplement the hydrogen monitors.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/06-0095 Page 3 of 4 The requirement for maintaining a hydrogen monitoring system designed to the Category 3 criteria of Regulatory Guide 1.97 will be included in the Updated Final Safety Analysis Report (UFSAR) in the next UFSAR update following implementation of the proposed TS amendment.

Based on the preceding analysis, removal of the hydrogen monitor requirements from the HBRSEP, Unit No. 2, TS is justified.

No Significant Hazards Consideration Determination Carolina Power and Light Company, also known as Progress Energy Carolinas (PEC), Inc., is proposing a change to Appendix A, Technical Specifications, of Facility Operating License No. DPR-23, for the H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2. The proposed change deletes the requirements for containment hydrogen monitors from Technical Specifications Section 3.3.3.

Carolina Power and Light Company has reviewed the proposed No Significant Hazards Consideration Determination published on September 25, 2003 (68 FR 55416), as part of the Consolidated Line Item Improvement Process (CLIIP). Carolina Power and Light Company has concluded that the proposed determination presented in the notice, as related to hydrogen monitors, is applicable to HBRSEP, Unit No. 2, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

Environmental Impact 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 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. Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc., has reviewed this request and determined that 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. The basis for this determination follows.

Proposed Change Carolina Power and Light Company, also known as Progress Energy Carolinas (PEC), Inc., is proposing a change to Appendix A, Technical Specifications, of Facility Operating License No. DPR-23, for the H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2. The proposed change deletes the requirements for containment hydrogen monitors from Technical Specifications Section 3.3.3.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/06-0095 Page 4 of 4 Basis Carolina Power and Light Company has reviewed the environmental evaluation included in the Model Safety Evaluation published on September 25, 2003 (68 FR 55416), as part of the Consolidated Line Item Improvement Process (CLIIP). Carolina Power and Light Company has concluded that the staff's findings presented in that evaluation, as related to hydrogen monitors, are applicable to HBRSEP, Unit No. 2, and the evaluation is hereby incorporated by reference for this application.

United States NLIclear Regulatory Commission Attachment III to Serial: RNP-RA/06-0095 4 Pages (including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE TO SECTION 3.3.3 MARKUP OF TECHNICAL SPECIFICATIONS PAGES

PAM Instrumentation 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. NOTE C.1 Restore one channel 7 days Not applicable to to OPERABLE status.

hydrogen monitor C. One or more Functions with two required channels inoperable.

D. ---------NOTE --------- D.1 Restore required 7 days Only applicable to channel to OPERABLE Functions 3, 4, 19, status.

22, 23, and 24.

One or more Functions with one required channel inoperable.

E-- Two hydrogen monitoer- 4 Restore one hydrpoge 72 h..

channels inoperable, monitor channel to OPE-R.ABL-E statuS.

FE. Required Action and .FE.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C 9-, Table 3.3.3-1 for the or E-D not met. channel.

GF. As required by GF.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 /> Required Action FE.1 and referenced in AND Table 3.3.3-1.

GF.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 /> (continued)

HBRSEP Unit No. 2 3.3-30 Amendment No. 17-6

PAM Instrumentation 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME HG. As required by 14G.1 Initiate action in Immediately Required Action FE.1 accordance with and referenced in Specification 5.6.6.

Table 3.3.3-1.

SURVEILLANCE REQUIREMENTS

---

NOTE -------------------------------------

SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1; except Functions 9, 22, 23, and 24. SR 3.3.3.3 applies only to Functions 9, 22, 23, and 24.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.3.2 -------------------NOTE -------------------- 18 months Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION.

SR 3.3.3.3 -------------------NOTE -------------------- 18 months Verification of setpoint not required.

Perform TADOT.

HBRSEP Unit No. 2 3.3-31 Amendment No. 17-6

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM FUNCTION REQUIRED CHANNELS REQUIRED ACTION FE.1

1. Power Range Neutron Flux 2

2. Source Range Neutron Flux 2

3. Reactor Coolant System (RCS) Hot Leg 1 per loop Temperature

4. RCS Cold Leg Temperature 1 per loop GF

5. RCS Pressure (Wide Range) 2 GF

6. Refueling Water Storage Tank Level 2 GF

7. Containment Sump Water Level (Wide Range) 2 HG

8. Containment Pressure (Wide Range) 2 HG

9. Containment Isolation Valve Position 2 per penetration flow GF path (a)(b)

10. Containment Area Radiation (High Range) 2 NG

11. Hydrogen Monitors Not used G 2

12. Pressurizer Level GF

13. Steam Generator Water Level (Narrow Range) 2 per SG GF

14. Condensate Storage Tank Level 2 GF

15. Core Exit Temperature--Quadrant 1 GF 2 (c)

16. Core Exit Temperature--Quadrant 2 GF 2 (c)

17. Core Exit Temperature--Quadrant 3 2 (c)

GF

18. Core Exit Temperature--Quadrant 4 GF 2 (c)

19. Auxiliary Feedwater Flow SD AFW Pump 1 per SG HG MDAFW Pump 1 per SG HG

20. Steam Generator Pressure 2 per SG GF

21. Containment Spray Additive Tank Level 2 GaF

22. PORV Position (Primary) 1 14G

23. PORV Block Valve Position (Primary) 1 14G

24. Safety Valve Position (Primary) 1 WG (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed automatic containment isolation valve.

(c) A channel consists of one core exit thermocouple (CET).

HBRSEP Unit No. 2 3.3-32 Amendment No. 17-6

United States Nuclear Regulatory Commission Attachment IV to Serial: RNP-RA/06-0095 4 Pages (including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REOUEST FOR TECHNICAL SPECIFICATIONS CHANGE TO SECTION 3.3.3 RETYPED TECHNICAL SPECIFICATIONS PAGES

PAM Instrumentation 3.3.3 Actions (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more Functions C.1 Restore one channel 7 days with two required to OPERABLE status.

channels inoperable.

D. ---------NOTE--------- D.1 Restore required 7 days Only applicable to channel to OPERABLE Functions 3, 4, 19, status.

22, 23, and 24.

One or more Functions with one required channel inoperable.

E. Required Action and E.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C Table 3.3.3-1 for the or D not met. channel.

F. As required by F.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 /> Required Action E.1 AND and referenced in Table 3.3.3-1. F.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 /> (continued)

HBRSEP Unit No. 2 3.3-30 Amendment No.

PAM Instrumentation 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. As required by G.1 Initiate action in Immediately Required Action E.1 accordance with and referenced in Specification 5.6.6.

Table 3.3.3-1.

SURVEILLANCE REQUIREMENTS

---

NOTE -------------------------------------

SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1; except Functions 9, 22, 23, and 24. SR 3.3.3.3 applies only to Functions 9, 22, 23, and 24.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.3.2 ------------------NOTE -------------------- 18 months Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION.

SR 3.3.3.3 -------------------NOTE ------------------ 18 months Verification of setpoint not required.

Perform TADOT.

HBRSEP Unit No. 2 3.3-31 Amendment No.

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM FUNCTION REQUIRED CHANNELS REQUIRED ACTION E.1

1. Power Range Neutron Flux 2

2. Source Range Neutron Flux 2

3. Reactor Coolant System (RCS) Hot Leg 1 per loop Temperature

4. RCS Cold Leg Temperature 1 per loop

5. RCS Pressure (Wide Range) 2

6. Refueling Water Storage Tank Level 2

7. Containment Sump Water Level (Wide Range) 2

8. Containment Pressure (Wide Range) 2

9. Containment Isolation Valve Position 2 per penetration flow path (a)(b)

10. Containment Area Radiation (High Range) 2

11. Not used

12. Pressurizer Level 2

13. Steam Generator Water Level (Narrow Range) 2 per SG

14. Condensate Storage Tank Level 2

15. Core Exit Temperature--Quadrant 1 2 (c)

16. Core Exit Temperature--Quadrant 2 2 (c)

17. Core Exit Temperature--Quadrant 3 2 (c)

18. Core Exit Temperature--Quadrant 4 2 (c)

19. Auxiliary Feedwater Flow SD AFW Pump 1 per SG MDAFW Pump 1 per SG

20. Steam Generator Pressure 2 per SG

21. Containment Spray Additive Tank Level 2

22. PORV Position (Primary) 1

23. PORV Block Valve Position (Primary) 1

24. Safety Valve Position (Primary) 1 (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed automatic containment isolation valve.

(c) A channel consists of one core exit thermocouple (CET).

HBRSEP Unit No. 2 3.3-32 Amendment No.