RNP-RA/13-0017, Response to Request for Additional Information for Review Regarding Steam Generator License Amendment Request to Revise Technical Specifications for Steam Generator Permanent Alternate Repair Criteria

Response to Request for Additional Information for Review Regarding Steam Generator License Amendment Request to Revise Technical Specifications for Steam Generator Permanent Alternate Repair Criteria

ML13072A300
Person / Time
Site:	Robinson
Issue date:	03/06/2013
From:	Wheeler S Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/13-0017
Download: ML13072A300 (4)

Text

S Duke Sharon A. Wheeler H. B. Robinson Steam Electric Plant Unit 2 Manager - Support Services Duke Energy 3581 West Entrance Road Hartsville, SC 29550 Serial: RNP-RA/13-0017 10 CFR 50.90 MAR 0 6 2013 ATTN: Document Control Desk U.S. 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 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR REVIEW REGARDING STEAM GENERATOR LICENSE AMENDMENT REQUEST TO REVISE TECHNCIAL SPECIFICATIONS FOR STEAM GENERATOR PERMANENT ALTERNATE REPAIR CRITERIA By letter to the U. S. Nuclear Regulatory Commission (NRC) dated August 29, 2012, (Agencywide Documents Access and Management System Accession No. ML12251A363),

Carolina Power and Light Company, now doing business as Progress Energy, submitted a license amendment request (LAR) which combined two proposed changes that affect the same Technical Specification (TS) sections. The first part proposes to implement revisions consistent with TS Task Force-5 10 (TSTF-5 10), Revision 2, "Revision to Steam Generator Inspection Frequencies and Tube Sample Selection." The second part proposes to exclude portions of the steam generator tube below the top of the steam generator tubesheet from periodic inspections by implementing the permanent alternate repair criteria "H*."

By letter dated February 4, 2013, (ADAMS Accession No. ML13017A288) the NRC staff requested additional information needed to continue its review of the proposed license amendment.

Progress Energy's response to the request for additional information is provided in the enclosure to this letter.

This letter contains the following new Regulatory Commitments:

Submit a revised license amendment request regarding Steam Generator program inspection frequencies and tube sample selection, and application of permanent alternate repair criteria (H*), by April 10, 2013.

If you have any questions concerning this matter, please contact Mr. Richard Hightower, Supervisor - Licensing/Regulatory Programs at (843) 857-1329.

Aoo / .

United States Nuclear Regulatory Commission Serial: RNP-RA/13-0017 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed On:

MAR 0 6 2013 Sincerely, Sha l eeler Manager - Support Services - Nuclear SAW/jk

Enclosure:

Response to Request for Additional Information Regarding H. B. Robinson Steam Electric Plant, Unit 2 The Steam Generator License Amendment Request to Revise Technical Specification for Permanent Alternate Repair Criteria c: Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)

Mr. V. M. McCree, NRC, Region II Ms. A. T. Billoch-Colon, NRC Project Manager, NRR NRC Resident Inspector, HBRSEP Unit No. 2 Mr. A. Wilson, Attorney General (SC)

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0017 Page 1 of 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 THE STEAM GENERATOR LICENSE AMENDMENT REQUEST TO REVISE TECHNCIAL SPECIFICATION FOR PERMANENT ALTERNATE REPAIR CRITERIA NRC REQUEST FOR ADDITIONAL INFORMATION (RAI)

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 29, 2012 (Agencywide Documents Access and Management System Accession No. ML12251A363),

Carolina Power & Light Company (the licensee), doing business as Progress Energy Carolinas, submitted a license amendment request (LAR) for H. B. Robinson Steam Electric Plant, Unit 2 (HBRSEP). The proposed LAR combines two changes that affect the same technical specification (TS) sections. The first part proposes to implement revisions consistent with Technical Specification Task Force-5 10, Revision 2, "Revision to Steam Generator Program Inspection Frequencies and tube Sample Selection." The second part proposes to permanently revise TS 5.5.9 "Steam Generator Program" to exclude portions of the steam generator tube below the top of the steam generator tubesheet from periodic inspections by implementing the permanent alternate repair criteria "H*." to the letter dated August 29, 2012, is a Westinghouse letter (LTR-SGMP-12-30 dated May 7, 2012) addressing the applicability of H* and the recommended leakage factor for HBRSEP, given the fact that HBRSEP has implemented a Measurement Uncertainty Recapture Power Uprate.

On pages 2 and 3 of Attachment 6, two tables from the references within Attachment 6 are reproduced. Upon review of the table on page 2, and comparison to Tables 5-1 and 9-5 of WCAP-17091-P (which is Reference 3 of Attachment 6), it isnot clear if the hot leg temperature provided in these three tables represents a low Tavg, a high Tavg, or a nominal Tavg condition for HBRSEP. As it appears that hot leg temperature has a significant effect on secondary pressure (e.g., see the large secondary pressure change between high Tavg to low Tavg at Turkey Point Units 3 and 4 in Table 9-5).

The NRC staff requests the following additional information related to your submittal:

1. Determine the low Tavg and high Tavg hot leg temperatures for HBRSEP. Then determine if the differential pressure across the tubesheet for HBRSEP continues to be bounded by the H* analysis for Turkey Point Units 3 and 4, when the low Tavg hot leg temperature is used in the HBRSEP H* analysis.

2. Provide the results of the above requested analysis.

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0017 Page 2 of 2 PROGRESS ENERGY RESPONSE Engineering Change (EC) 90553, "Input for NRC Request for Additional Information Regarding Alternate Repair Criteria" was performed and yielded results as shown below:

RCS SG Tubesheet (psia) RCS Conditions Conditions Tavg Tcold Thot Psteam RCS-SG 2250 (OF) (OF) (OF) (psia) psi Low Tavg 571.9 543.1 600.7 773.6 1476.4 High Tavg 579.9 551.5 608.3 833.9 1416.1 As stated in the NRC Request for Additional Information, the critical parameter for the structural analysis is the normal operating parameters (NOP) condition low Tavg secondary pressure because this pressure dictates the largest tube end-cap (pull-out) loads on the tubes.

The following is a comparison of the H. B. Robinson low Tavg data with the Turkey Point data, provided on page 3 to attachment 6 of RNP-RA/12-0057, License Amendment Request for Revision to Steam generator Program Inspection frequencies and Tube Selection and Application of Permanent Alternate Repair Criteria (H*).

Parameter and Units Turkey Point Robinson Power - NSSS MWth 2652 2239 Primary Pressure psia 2250 2250 Secondary Pressure psia 701 773.6 SG Hot Leg Temperature OF 604.5 600.7 SG Primary-to-secondary Pressure Psid 1549 1476.4 Differential (psid) Across Tubesheet Turkey Point Units 3 and 4 exhibits a lower secondary pressure for the low Tavg under NOP condition (701 psia); therefore, it bounds the secondary pressure under the same condition for HBRSEP Unit 2 (773.6 psia). Based upon this, the applicable H* inspection criterion for HBRSEP is 18.11 inches as described in the August 29, 2012 License Amendment Request.

During the development of this response it was determined that the appropriate leakage factor for HBRSEP Unit 2 should be 1.87 rather than 1.82 as previously reported. As a result, it will be necessary to revise our August 29, 2012, License Amendment Request. We expect to provide the revised request by April 10, 2013.