RNP-RA/14-0077, Response to NRC Request for Additional Information Regarding License Amendment Request to Modify Technical Specification 3.1.7 to Delete the Monthly Rod Position Indication Surveillance Requirements

Response to NRC Request for Additional Information Regarding License Amendment Request to Modify Technical Specification 3.1.7 to Delete the Monthly Rod Position Indication Surveillance Requirements

ML14219A010
Person / Time
Site:	Robinson
Issue date:	07/24/2014
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/14-0077
Download: ML14219A010 (5)

Text

W R. Gideon H. B. Robinson Steam Electric Plant Unit 2 DUKE Site Vice President Duke Energy Progress E E Y3581 West Entrance Road Hartsville, SC 29550 PROGRESS 0:843 8571701 F: 843 857 1319 Randy. Gideon6duke-energy con.

10 CFR 50.90 Serial: RNP-RAI14-0077 JUL 2 4 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23

Subject:

Response to NRC Request for Additional Information Regarding License Amendment Request to Modify Technical Specification 3.1.7 to Delete the Monthly Rod Position Indication Surveillance Requirements

References:

1. NRC Letter to William R. Gideon, H. B. Robinson Steam Electric Plant, Unit 2 - Request for Additional Information Regarding Technical Specification 3.1.7 Deletion of Monthly Rod Position Indication Surveillance Requirements (TAC No. MF1966); dated July 8, 2014, (Agencywide Documents Access and Management System (ADAMS) Accession

.No. ML14183B598).

2. i'cense Amendment Request to Modify Technical Specification 3.1.7 to Delete the Monthly Rod Position Indication Surveillance Requirements, dated June 7, 2013 (ADAMS Accession No. ML13182A019).,

Ladies and Gentlemeen:

By letter (Reference 2) to the U. S. Nuclear Regulatory Commission (NRC) dated June 7, 2013, (ADAMS Accession No. ML13182A019), Duke Energy Progress, Inc. submitted a license amendment request (LAR) for H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2).

The proposed LAR would delete the current HBRSEP2 Surveillance requirements 3.1.7.1, 3.1.7.2, and 3.1.7.3 of Technical Specification (TS) 3.1.7, "Rod Position Indication," and renumber current SR 3.1.7.4 as SR 3.1.7.1. This change deletes a redundant surveillance requirement and eliminates a minimum of eight reactivity manipulations per year.

By letter dated Ju'ly'8 2014, (ADAMS Accession No. ML14183B598) (Reference 1) the NRC staff requested additional information needed to continue its review of the proposed license amendment. . It Duke Energ~y's response to the request for additional information is provided in the enclosure to this letter.

.,...I . ,. .,., -..

U. S. Nuclear Regulatory Commission Serial: RNP-RA/14-0077 Page 2 of 2 This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

Should you have any questions regarding this submittal, please contact Mr. Richard Hightower, Manager, Nuclear Regulatory Affairs at (843) 857-1329.

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

Executed on -- 24 -

Sincerely, W. R. Gideon Site Vice President WRG/jmw

Enclosure:

H. B. Robinson Steam Electric Plant, Unit No. 2 Response to the NRC Request for Additional Information Regarding License Amendment Request to Modify TS 3.1.7 to Delete the Monthly Rod Position Indication Surveillance Requirements cc: Mr. K. M. Ellis, NRC Senior Resident Inspector Ms. Martha C. Barillas, NRC Project Manager, NRR Mr. V. M. McCree, NRC Region II Administrator

U. S. Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/1 4-0077 Page 1 of 3 Enclosure H. B. Robinson Steam Electric Plant, Unit No. 2 Response to the NRC Request for Additional Information Regarding License Amendment Request to Modify TS 3.1.7 to Delete the Monthly Rod Position Indication Surveillance Requirements

U. S. Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/14-0077 Page 2 of 3 NRC REQUEST FOR ADDITIONAL INFORMATION (RAI)

By letter dated June 7, 2013 (Agencywide Documents Access and Management System Accession No. ML13182A019), Duke Energy Progress, Inc. (the licensee), requested a license amendment to delete the current H. B. Robinson Steam Electric Plant, Unit 2, Surveillance Requirements (SRs) 3.1.7.1, 3.1.7.2, and 3.1.7.3 of Technical Specification 3.1:7, "Rod Position Indication," and renumber current SR 3.1.7.4 as SR 3.1.7.1.

To complete its review, the U. S. Nuclear Regulatory Commission (NRC) staff requests the following additional information:

1. On page 3 of 13, Section 2.0, Detailed Description, the licensee stated, "The 92 day FREQUENCY takes into consideration other information available to the operator in the control room and SR 3.1.4.1, which is performed more frequently, adds to the determination of OPERABILITY of the rods. Deletion of SRs 3.1.7.2 and 3.1.7.3 will result in less frequent rod motion being required (every 92 days instead of 31), as well as less rod motion (10 steps instead of 19) being required during performance of the surveillance to confirm analog rod position indication system and bank demand position indication system capability to respond to rod motion. The deletion of these SRs will eliminate a monthly reactivity manipulation (reduction of reactor power to less than 98%) to meet the 19 step rod motion requirement."

The licensee is requested to provide the frequency and the description of "the other information available to the operator in the control room." This information is needed by NRC staff to assess the acceptability of the change from 31 days to 92 days.

2. Title 10 of the Code of Federal Regulations, Section 50.36(c)(3), Surveillance Requirements, states surveillance requirements are requirements relating to test.

calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. State whether the proposed rod position indication accuracy is affected. If the proposed alternate rod position indication accuracy is affected, address the acceptability of the lower accuracy.

U. S. Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/14-0077 Page 3 of 3 Duke Energy Response to RAI 1:

As stated in paragraph four of page 4 of 13 of the Enclosure to the subject submittal (Serial RNP-RA/1 3-0002), the rod control system also includes a deviation monitor which continuously compares the outputs of the bank (group) demand (step counter) position and analog rod position and actuates an alarm when the two position indications differ by more than a preselected value. Additionally, rod position indication is fed into the plant process computer and can be monitored for changes in individual control rod position. These two real-time sources of information provide operators accurate and continuous indication of control rod deviation and position.

Duke Energy Response to RAI 2:

Accuracy of the Rod Position Indication (RPI) system is based on the physical configuration associated with the coil stack and the drive shaft. The frequency of system calibrations will remain at 18 months, and, as stated in the RAI 1 Response, rod position indication can be monitored continuously via the deviation monitor and plant process computer. Additionally, the proposed change to SR 3.1.7 involves no physical change to the rod control system or to the RPI system and thus will not impact the accuracy or performance of the RPI system.