RNP-RA/07-0124, Request for Technical Specifications Change to Section 3.1.7 Rod Position Indication

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Request for Technical Specifications Change to Section 3.1.7 Rod Position Indication
ML073300458
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 11/15/2007
From: Baucom C
Progress Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/07-0124
Download: ML073300458 (19)
v • d • e


Text

10 CFR 50.90 Progress Energy Serial: RNP-RA/07-0124 NOV 1 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 3.1.7 ROD POSITION INDICATION 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. (PEC), 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 revise TS 3.1.7, "Rod Position Indication." The proposed change revises the requirements related to rod position indication. The requirements for one inoperable bank demand position indicator are proposed to be modified and a new condition, associated required actions, and completion times are proposed for two demand position indicators inoperable per bank for one or more banks.

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.

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 as rapidly as possible to provide an appropriate condition for two inoperable demand position indicators per bank for one or more banks.

Progress Energy Carolinas, Inc.

Robinson Nuclear Plant 3581 West Entrance Road Hartsville, SC 29550

United States Nuclear Regulatory Commission Serial: RNP-RA/07-0124 Page 2 of 2 If you have any questions concerning this matter, please contact me at (843) 857-1253.

Sincerely, C. T. Baucom Manager - Support Services - Nuclear Attachments:

I. Affirmation II. Request for Technical Specifications Changes Related to Rod Position Indication III. Markup of Technical Specifications Pages IV. Retyped Technical Specifications Pages CTB/cac c: Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)

Mr. A. Gantt, Chief, Bureau of Radiological Health (SC)

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

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/07-0124 Page 1 of 1 AFFIRMATION The information contained in letter RNP-RA/07-0124 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: , O T. D. Walt Vice President, HBRSEP, Unit No. 2

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0124 Page 1 of 9 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR TECHNICAL SPECIFICATIONS CHANGES RELATED TO ROD POSITION INDICATION Description of Current Condition Technical Specifications (TS) Limiting Condition for Operation (LCO) Section 3.1.7, "Rod Position Indication," provides the operability requirements, allowed conditions, required actions, completion times and surveillance requirements associated with the Rod Position Indication system. The TS LCO Section 3.1.7, Condition C, provides the required actions and completion times for one demand position indicator per bank inoperable for one or more banks. Required Action C. 1.1 requires verification by administrative means that all analog rod position indicators (ARPIs) for the affected banks are operable once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when one bank demand position indicator is inoperable. There is no condition provided for two demand position indicators per bank inoperable for one or more banks.

Description and Justification of the Proposed Changes The proposed changes include deletion of Required Action C. 1.1 and the addition of a new condition, required actions, and completion times for the condition of two demand position indicators per bank inoperable for one or more banks. A description of the Rod Position Indication system is provided in the bases for LCO 3.1.7. A summary of the Rod Position Indication system as described in the bases for LCO 3.1.7 is provided as follows:

"The axial position of shutdown rods and control rods are determined by two separate and independent systems: the Bank Demand Position Indication System (commonly called group step counters) and the Analog Rod Position Indication (ARPI) System.

The Bank Demand Position Indication System counts the pulses from the Rod Control System that move the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The Bank Demand Position Indication System is considered highly precise (+/- 1 step or +/- 5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod.

The ARPI System provides a highly accurate indication of actual control rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of coils spaced along a hollow tube with a center to center distance of 3.75 inches, which is 6 steps. Therefore, the normal indication accuracy of the ARPI System is +/- 6 steps

(+/- 3.75 inches), and the maximum uncertainty is +/- 12 steps (+/- 7.5 inches). With an indicated deviation of 12 steps between the group step counter and ARPI, the maximum deviation between actual rod position and the demand position could be 24 steps, -or 15 inches."

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0124 Page 2 of 9 The proposed deletion of Required Action C. 1.1 is needed to avoid unnecessary power reduction to 50%. As currently written, Required Action C. 1.1 prevents any inoperable ARPIs in the same bank with one inoperable demand position indicator. Therefore, power reduction to _*50% would be required for an inoperable ARPI in the same bank as an inoperable demand position indicator, in accordance with the current Required Action C.2, or Required Action D. 1 if> 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> have elapsed since entry into Condition C. The requirement to verify ARPI operability in Required Action C. 1.1 is not necessary because Condition A of LCO 3.1.7 already provides the appropriate required actions for one inoperable ARPI per group. LCO 3.1.7, Condition A, requires verification of rod position (for the rod with the inoperable ARPI) once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> by use of the movable incore detectors.

Required Actions C. 1.2 and C. 1.3 are being renumbered to C. 1.1 and C. 1.2. These two required actions provide the requirements for verification of the position of each rod in the affected bank. If an ARPI is inoperable, the requirements of LCO 3.1.7, Condition A, will provide verification of the rod position using the movable incore detectors once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, which allows the completion of the renumbered Required Actions C. 1.1 and C. 1.2 (C. 1.2 and C. 1.3 in the current TS), which are also once per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completion times.

The proposed new Condition D will establish the required actions and associated completion times for two inoperable bank demand position indicators per bank in one or more banks. Required Action D.1 will require placing the rod control system in manual and suspending movement of the affected bank(s) immediately. This will prevent further changes in rod position until at least one bank demand position indicator is restored for the affected bank(s). Required Action D.2 provides 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for restoration of one of the two inoperable bank demand position indicators in the affected bank(s). The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completion time is appropriate based on the remaining available ARPI that provide indication of the position of the control rods and the completion of Required Action D. 1, which keeps the control rods in the affected banks at a constant position until at least one demand position indication is restored. If the required actions and associated completion time of Condition D are not met, Condition E (previously designated Condition D) would be entered, which requires the unit to be placed in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The proposed action to place the rod control system in manual and suspension of movement of the affected bank(s) normally cannot be met during operability testing of the affected bank demand position indicator. Therefore, LCO 3.0.5 can be invoked to allow not meeting proposed Required Action D. 1 during operability testing of the affected bank demand indicator to restore the indicator to operable status.

The required actions for proposed LCO 3.1.7, Condition D, are modified by a note that identifies the surveillance requirements and required action that are not required to be met during the time that no demand position indication is available in a bank. Specifically, the proposed note states that Surveillance Requirement (SR) 3.1.4.1, SR 3.1.5.1, SR 3.1.6.2, and LCO 3.1.7, Required Action C. 1.2, are not required to be met for the affected bank(s) until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after completion of Required Action D.2. This note is necessary to provide guidance for the surveillances and the action statement that cannot be met when both demand position indicators are inoperable for a bank.

The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time after restoration of one demand position indicator allows time to conduct the required surveillances. This could allow up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for restoration of one indicator

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0124 Page 3 of 9 plus 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to conduct the surveillances). This time is appropriate and is justifiable based on the inoperabilities that have occurred. This LCO and its associated actions are provided for inoperability of rod position indication. There are no circumstances or postulated malfunctions in the rod position indication system that could cause one or more control rods being out of position, provided no rod movements of the affected bank have occurred while the two bank demand position indicators were inoperable. Therefore, prevention of rod movement during this condition is appropriate and the additional time to conduct required surveillances is justified.

If the failure of two bank demand position indicators were to occur during performance of SR 3.1.4.2, then the Applicability notes provided in LCO 3.1.5 and LCO 3.1.6 that state these LCOs are not required to be met, shall remain in effect until one demand position indicator is restored.

The SR 3.1.4.2 testing is currently conducted in conjunction with SR 3.1.7.2 and SR 3.1.7.3, which require movement of the bank Ž__ 19 steps to verify position indication system response. The use of the Applicability notes in LCO 3.1.5 and 3.1.6, when Condition D is entered during rod movement testing, will allow the insertion limit LCO for the bank being tested to be not met for some additional time. This is justified based on the testing remaining in progress until the rods are restored to the required positions and that there is no TS time limit specified for the testing.

Additionally, the applicable core power distribution limits specifications (i.e., LCO 3.2.1 Heat Flux Hot Channel Factor, LCO 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor, LCO 3.2.3 Axial Flux Difference, and LCO 3.2.4 Quadrant Power Tilt Ratio) remain in effect in accordance with the Applicability requirements for these specifications.

The actions table for LCO 3.1.7 is modified by a note that allows separate condition entry for each inoperable rod position indicator per group and each demand position indicator per bank. This note will be applicable to the proposed Condition D. Entry into Condition D will be required anytime two demand position indicators are inoperable in one or more banks. The completion time for each bank with two inoperable demand position indicators would be 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from entry into Condition D, consistent with Completion Time Example 1.3-5 in Section 1.0 of the Technical Specifications.

As previously described, there are two demand position indicators per bank. Each bank is divided into two groups of rods that move in a staggered fashion within one step of each other. This is described in the bases for TS LCO 3.1.4 as follows:

"The OPERABILITY (e.g., trippability) of the shutdown and control rods is an initial assumption in all safety analyses that assume rod insertion upon reactor trip. Maximum rod misalignment is an initial assumption in the safety analysis that directly affects core power distributions and assumptions of available SDM [Shutdown Margin].

The applicable criteria for these reactivity and power distribution design requirements are described in the UFSAR [Updated Final Safety Analysis Report] and 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Plants."

Mechanical or electrical failures may cause a control rod to become inoperable or to become misaligned from its group. Control rod inoperability or misalignment may cause

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0124 Page 4 of 9 increased power peaking, due to the asymmetric reactivity distribution and a reduction in the total available rod worth for reactor shutdown. Therefore, control rod alignment and OPERABILITY are related to core operation in design power peaking limits and the core design requirement of a minimum SDM.

Limits on control rod alignment have been established, and all rod positions are monitored and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.

Rod cluster control assemblies (RCCAs), or rods, are moved by their control rod drive mechanisms (CRDMs). Each CRDM moves its RCCA one step (approximately 5/8 inch) at a time, but at varying rates (steps per minute) depending on the signal output from the Rod Control System.

The RCCAs are divided among control banks and shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control. A group consists of two or more RCCAs that are electrically paralleled to step simultaneously. A bank of RCCAs consists of two groups that are moved in a staggered fashion, but always within one step of each other. HBRSEP has four control banks and two shutdown banks.

The shutdown banks are maintained either in the fully inserted or fully withdrawn position.

The control banks are moved in an overlap pattern, using the following withdrawal sequence: When control bank A reaches a predetermined height in the core, control bank B begins to move out with control bank A. Control bank A stops at the position of maximum withdrawal, and control bank B continues to move out. When control bank B reaches a predetermined height, control bank C begins to move out with control bank B. This sequence continues for the remaining control banks. The insertion sequence is the opposite of the withdrawal sequence. The control rods are arranged in a radially symmetric pattern, so that control bank motion does not introduce radial asymmetries in the core power distributions.

The axial position of shutdown rods and control rods is indicated by two separate and independent systems, which are the Bank Demand Position Indication System (commonly called group step counters) and the Analog Rod Position Indication (ARPI) System.

The Bank Demand Position Indication System counts the pulses from the rod control system that moves the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The Bank Demand Position Indication System is considered highly precise (+/- 1 step or +/- 5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod.

The ARPI System provides a highly accurate indication of actual control rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of coils spaced along a hollow tube with a center'to center distance of

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0124 Page 5 of 9 3.75 inches, which is six steps. The maximum uncertainty of the ARPI System is +/-12 steps

(+/- 7.5 inches). With an indicated deviation of 12 steps between the group step counter and ARPI, the maximum deviation between actual rod position and the demand position could be 24 steps, or 15 inches."

The proposed Condition D provides required actions and completion times for two inoperable demand position indicators per bank. In this condition, there are no operable demand position indicators in the bank that can be used for comparison to the ARPIs in that bank. As previously stated, under this condition suspending movement of the affected bank reduces the likelihood that an undetected rod misalignment can occur. Although, rod misalignment could be detected using the ARPIs and the movable incore detector system, if necessary.

When one bank demand position indicator is inoperable Condition C applies. The required surveillances and applicable required actions can be met under this condition because the operable demand position indicator for the bank can be used.

The rod position indication system is not modeled in the HBRSEP, Unit No. 2, probabilistic safety assessment (PSA). The PSA model does include failure of the reactor to trip and failure of control rods due to mechanical binding, but these conditions are unaffected by the proposed TS changes.

The proposed changes will not alter the ability to detect untrippable control rods. Additionally, the proposed Required Action D. 1 would not preclude the use of the control rod system in manual mode to mitigate an Anticipated Transient Without Scram (ATWS), because failure to meet Condition D. 1 would require entry into Condition E, which requires the unit to be placed in MODE 3 with 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Therefore, the PSA results associated with the ability of the operator to use manual rod control to mitigate an ATWS event are unaffected.

Placing the rod control system in manual and suspending motion of the affected bank(s) as directed by proposed Required Action D. 1 does prevent the rod control system from automatically responding to a transient condition. Although not quantified, this could cause a very small increase in the likelihood of a reactor trip while the rod control system is in manual control (see UFSAR, Section 7.7.1.1, for a description of the rod control system). This minor change in reactor trip probability is considered to be less significant than the operational concerns posed by leaving the rod control system in automatic with no operable bank demand position indicators for the affected bank(s). There is no TS limitation on operation with the rod control system in manual.

Additionally, the current requirements of the HBRSEP, Unit No. 2, TS would require entry into LCO 3.0.3 when two bank demand position indicators are inoperable in one or more banks. The proposed condition, required actions, and completion times will reduce the likelihood that a shutdown of the reactor will be required for this condition, thereby avoiding placing the unit in a transient condition while there is no demand position indication available for one or more banks.

Comparison of the HBRSEP, Unit No. 2, TS to the guidance in NUREG- 1431, "Standard Technical Specifications - Westinghouse Plants," Revision 3, showsthat the current TS requirements for HBRSEP, Unit No. 2, are different than the guidance contained in NUREG-143 1. These differences are based on justification of deviations from NUREG- 1431 that were included in the license amendment associated with the conversion to Improved Standard Technical Specifications that was approved by the NRC in letter dated October 24, 1997. The current.TS include an identical

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0124 Page 6 of 9 condition to the NUREG-1431 guidance that is applicable to one demand position indicator per bank inoperable for one or more banks. The required actions are also similar. The proposed deletion of HBRSEP, Unit No. 2, TS Required Action C. 1.1 to verify by administrative means that all ARPIs for the affected bank are operable is a less restrictive change to the current TS and a deviation from the NUREG- 1431 guidance. The justification for this change (as provided previously) states that this requirement is unnecessary because Required Action A. 1 provides the requirement to verify rod position for a rod with an inoperable ARPI and at least one demand position indicator remains operable for rod position comparison if only one demand position indicator is inoperable in the affected bank.

The proposed new Condition D is also less restrictive than the current TS requirements and a deviation from NUREG- 1431 guidance. A Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications Change Traveler, designated TSTF-437-T, Revision 1, is available and provides one possible approach to correct the apparent error in NUREG- 1431 for the absence of a condition associated with more than one inoperable demand position indicator in a bank for one or more banks. The change described by TSTF-437-T allows the current condition for one inoperable demand position indicator to be used for more than one demand position indicator inoperable in a bank. Based on the current HBRSEP, Unit No. 2, TS requirements, this approach is not considered appropriate. As previously described in this TS change justification, two inoperable bank demand position indicators cause several other TS requirements to be not met, and therefore specific required actions and specific allowance for these circumstances is considered necessary for HBRSEP, Unit No. 2.

The preceding justifications provide the basis for the proposed changes. This TS change is being proposed at this time due to an inoperability of three demand position indicators (Shutdown Bank A Group 2, Control Bank A Group 2, and Control Bank C Group 2) and the determination that both demand position indicators for the three control rod banks (Shutdown Bank A and Control Banks A and C) would be made inoperable for a brief period in order to correct the malfunction. Therefore, this proposed TS change would establish a condition for inoperability of two demand position indicators for one or more banks. Additionally, during the preparation of this change it was noted that Required Action C. 1..1 is not needed and it is therefore proposed to be deleted. This proposed change is requested as rapidly as possible to allow appropriate TS requirements for repair of the rod position indication system.

No Significant Hazards Consideration Determination Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. (PEC), 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 revises the requirements related to Limiting Condition for Operation (LCO) Section 3.1.7, Rod Position Indication. The requirements for one inoperable bank demand position indicator is proposed to be modified and a new condition, associated required actions, and completion times are proposed for two demand position indicators inoperable per bank for one or more banks.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0124 Page 7 of 9 An evaluation of the proposed change has been performed in accordance with 10 CFR 50.91 (a)(1) regarding no significant hazards considerations, using the standards in 10 CFR 50.92(c). A discussion of these standards as they relate to this amendment request follows:

I1. The Proposed Change Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.

The proposed change provides revised requirements for one demand position indicator inoperable and new requirements for two demand position indicators inoperable in one or more banks. The proposed change provides appropriately limiting requirements for these conditions. Additionally, the applicable core power distribution limits specifications (i.e.,

LCO 3.2.1 Heat Flux Hot Channel Factor, LCO 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor, LCO 3.2.3 Axial Flux Difference, and LCO 3.2.4 Quadrant Power Tilt Ratio) remain in effect in accordance with the Applicability requirements for these specifications. This ensures that the core power distribution remains within TS requirements or appropriate actions shall be taken. The proposed changes do not affect the automatic shutdown capability of the reactor protection system and no accident analyses are impacted by the proposed changes.

Therefore, 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 evaluated.

2. The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident From Any Previously Evaluated.

As described above, the proposed change provides revised requirements for one demand position indicator inoperable and new requirements for two demand position indicators inoperable in one or more banks. The proposed change provides appropriately limiting requirements for these conditions. No new accident initiators are introduced by the proposed requirements. The proposed change does not affect the reactor protection system or the reactor control system. Hence, no new failure modes are created that would cause a new or different kind of accident from any accident previously evaluated.

Therefore, 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 previously evaluated.

3. The Proposed Change Does Not Involve a Significant Reduction in the Margin of Safety.

The Bases of TS 3.1.7 states that the operability of the rod position indicators is required to determine control rod positions and thereby ensure compliance with the control rod alignment and insertion limits. The proposed change does not alter the requirement to determine rod position, but provides revised requirements for one demand position indicator inoperable and new requirements for two demand position indicators inoperable in one or more banks. The proposed change provides appropriately limiting requirements for these

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0124 Page 8 of 9 conditions. As a result, the initial conditions of the accident analyses are preserved, and the consequences of previously analyzed accidents are unaffected.

Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant reduction in the margin of safety.

Based on the above discussion, Carolina Power and Light Company has determined that the requested change does not involve a significant hazards consideration.

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 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, Inc. (PEC), is proposing a change to Appendix A, Technical Specifications (TS), of Facility Operating License No. DPR-23, for the H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2. The proposed change revises the requirements related to rod position indication. The requirements for one inoperable bank demand position indicator are proposed to be modified and a new condition, associated required actions, and completion times are proposed for two demand position indicators inoperable per bank for one or more banks.

Basis The proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

1. As demonstrated in the No Significant Hazards Consideration Determination, the proposed change does not involve a significant hazards consideration.
2. As demonstrated in the No Significant Hazards Consideration Determination, the proposed change does not result in a significant increase in the consequences of an accident previously evaluated and does not result in the possibility of a new or different kind of accident.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0124 Page 9 of 9 Therefore, the proposed change does not result in a significant change in the types or significant increases in the amounts of any effluents that may be released offsite.

3. The proposed change does not alter any parameters from which the individual and cumulative radiation exposure for HBRSEP, Unit No. 2, results. Therefore, the proposed change does not result in a significant increase in individual or cumulative occupational radiation exposures.

United States Nuclear Regulatory Commission Attachment III to Serial: RNP-RA/07-0124 4 Pages (including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR TECHNICAL SPECIFICATIONS CHANGES RELATED TO ROD POSITION INDICATION MARKUP OF TECHNICAL SPECIFICATIONS PAGES

Rod Puziilior IridicaLion 3.1.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to s 50% RTP.

C. One demand position C.1.1 "-rif, by 9ee;-

indicator per bank -adm4i;ni-4Fit mea.. 8-ours inoperable for one or &+ . .AR.f.

s L...

more banks. aff*cted banks am C.1./ ........ NOTE .........

Only required to be met for bank positions < 200 steps.

Verify the position Once per of each rod in the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> affected bank(s) is within 7.5 inches of the average of the individual rod positions in the affected bank(s).

AND (continued)

HRRSEP Unit No. 2 3-1-16 Ampndment No. .1-K

Rod Position Indication 3.1.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C1 ........ NOTE .........

Only required to be met for bank positions a 200 steps.

Verify the position Once per of each rod in the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> affected bank(s) is within 15 inches of the bank demand position.

OR C.2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to s 50% RTP.

+/-;

,W' Required Action and associated Completion Time not met.J Xf.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 /> HBRSEP Unit No. 2 3.1-17 Amendment No. -?T

I Insert NOTE------- --------

U. Two demand position SR 3-1-4-1. SR 3.-15-1.

indicators per bank SR 3.1.6.2. and Required inoperable for one Action C-1-2 are not or more banks. required to be met for the affected bank(s) until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after completion of Required Action D.2.

D-1 Place the control Immediately rods under manual control and suspend movement of the affected bank(s).

AND D.2 Restore one demand 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> position indicator per bank.

United States Nuclear Regulatory Commission Attachment IV to Serial: RNP-RA/07-0124 3 Pages (including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR TECHNICAL SPECIFICATIONS CHANGES RELATED TO ROD POSITION INDICATION RETYPED TECHNICAL SPECIFICATIONS PAGES

Rod Position Indication 3.17 ACTIONS CONDITION REQUIRED ACTION CO1PLETION TIME B. (continued) Bý2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 5 50% RTP.

C. One demand position C.1.1 --------NOTE------

indicator per bank Only required to be inoperable for one or met for bank more banks. positions < 200 steps.

Verify the position Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of each rod in the affected bank(s) is within 7.5 inches of the average of the individual rod positions in the affected bank(s)-

AND C-1.2 --------

-- NOTE------

Only required to be I

met for bank positions t 200 steps.

Verify the position Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

of each rod in the affected bank(s) is within 15 inches of the bank demand position.

OR C.2 Reduce THERMAL POWER 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to . 50% RTP.

(continued)

HBRSEP Unit No. 2 3-1-16 Amendment No.

Rod Position Indication 3.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE-------

D. Two demand position SR 3.1.4.1. SR 3.1.5.1.

indicators per bank SR 3.1.6.2. and Required inoperable for one Action C.1.2 are not required or more banks. to be met for the affected bank(s) until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after completion of Required Action D.2.

D-1 Place the control rods Immediately under manual control and suspend movement of the affected bank(s).

AND D.2 Restore one demand 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> position indicator per bank.

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.

HBRSEP Unit No. 2 3-1-17 Amendment No-

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