RNP-RA/16-0072, Response to Request for Additional Information Regarding Application for Technical Specification Change to Adopt Technical Specifications Task Force (TSTF)-339, Relocate TS Parameters to the COLR Consistent with WCAP-14483, Rev. 2

Response to Request for Additional Information Regarding Application for Technical Specification Change to Adopt Technical Specifications Task Force (TSTF)-339, Relocate TS Parameters to the COLR Consistent with WCAP-14483, Rev. 2

ML16258A292
Person / Time
Site:	Robinson
Issue date:	09/14/2016
From:	Glover R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/16-0072, WCAP-14483, Rev. 2
Download: ML16258A292 (11)

Text

(~ DUKE R. Michael Glover H. B. Robinson Steam Electric Plant Unit 2 ENERGY~ Site Vice President Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 SEP 1 -4 20J8 0 : 843 857 1704 F: 843 857 1319 Mike.Glover@duke-energy.com Serial: RNP-RA/16-0072 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H. 8. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)-339, RELOCATE TS PARAMETERS TO THE COLA CONSISTENT WITH WCAP-14483, REVISION 2

Dear Sir/Madam:

By letter dated April 24, 2016 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML16116A033) Duke Energy Progress, Inc. (DEP) submitted a license amendment request (LAR) for H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). The proposed amendment would adopt Technical Specifications Task Force (TSTF)-339, Revision 2, "Relocate TS Parameters to the COLR," dated May 26, 2000 (ADAMS Accession No. ML003723269),

consistent with WCAP-14483, Revision 2, "Generic Methodology for Expanded Core Operating Limits Report," dated January 19, 1999 (ADAMS Accession No. ML003723269). This LAR would relocate Reactor Coolant System (RCS)-related cycle-specific parameters and core safety limits from the Technical Specifications (TS) to the Core Operating Limits Report (COLR).

The Nuclear Regulatory Commission (NRC) staff determined that additional information is needed to complete its LAR review. A draft of that information request was received by DEP via electronic mail message dated August 11, 2016, which provided three (3) requests for additional information (RAls). The DEP responses to these RAls are provided herein.

Please address any comments or questions regarding this matter to Mr. Tony Pile, Acting Manager

- Nuclear Regulatory Affairs at (843) 857-1409.

There are no new regulatory commitments made in this letter.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 5.c.~e.(" t\ I 2016.

Sincerely, C}~ f\ -\~ \;JR R. Michael Glover Site Vice President RMG/jmw

U. S. Nuclear Regulatory Commission Serial: RNP-RA/16-0072 Page2 Attachment - Response to Request for Additional Information Regarding License Amendment Request to Adopt Technical Specifications Task Force (TSTF)-339, Revision 2, "Relocate TS Parameters to the COLA" cc: Region Administrator, NRC, Region II Mr. Dennis Galvin, NRC Project Manager, NRR NRC Resident Inspector, HBRSEP2 Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)

U.S. Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0072 Page 1 of 9 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)-

339, REVISION 2, "RELOCATE TS PARAMETERS TO THE COLA"

U. S. Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0072 Page 2 of 9 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)-339, REVISION 2, "RELOCATE TS PARAMETERS TO THE COLR," CONSISTENT WITH WCAP-14483, REVISION 2, "GENERIC METHODOLOGY FOR EXPANDED CORE OPERATING LIMITS REPORT" DUKE ENERGY PROGRESS, INC.

DOCKET NO. 50-261 RAl-1 The licensee states in its application that the Limiting Condition for Operation (LCO) and Surveillance values in TS 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits," for RCS pressure and temperature do not currently account for instrument uncertainty and are therefore non-conservative. The LCO and surveillance values for RCS flow do account for instrument uncertainty. Administrative controls were implemented in accordance with the guidance in NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," dated December 19, 1998. These administrative controls were implemented to utilize conservative limits for RCS pressure and temperature that do account for instrument uncertainty. The licensee states it intends to incorporate RCS pressure and temperature LCO and surveillance values, which do account for instrument uncertainty, into the COLA as part of the implementation of the proposed amendment. It is unclear to the NRC staff what the uncertainty values are associated with the LCO and Surveillances for TS 3.4.1 for RCS pressure and temperature. In order to ensure that conservatism is preserved, the NRC staff requests that the licensee provide a discussion of the uncertainty values and their magnitudes for RCS pressure and temperature limits in TS 3.4.1 .

DEP Response:

As indicated in the Bases of Technical Specification 3.4.1, the Pressurizer pressure indications are averaged to come up with a value for comparison to the DNB Technical Specification limit. The uncertainty associated with the average Pressurizer pressure is dependent on the indicator used (Main Control Board meter or Plant Computer indication) and the number of operable channels used in the average (2 or 3 operable channels). The uncertainty associated with the average Pressurizer Pressure is as follows:

Number of Channels Main Control Board Plant Computer In Avera e Indicator Indication 3 Channels +/- 20.78 +/-14.41 2 Channels The above uncertainties include consideration of the uncertainty of all of the components included in the instrument loop which provide the indication (i.e. the pressure transmitter, isolator and indicator).

The Bases of Technical Specification 3.4.1 also indicates that the indications of temperature are averaged to determine a value for comparison to the Technical Specification limit. The uncertainty associated with the average RCS Tavg is also dependent on the indicator used (Main Control

U. S. Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0072 Page 3 of 9 Board meter or Plant Computer indication) and the number of operable channels used in the average (2 or 3 operable channels). The uncertainty associated with the average RCS Tavg is as follows:

Number of Channels Main Control Board Plant Computer In Average Indicator Indication 3 Channels +/- 2.27°F +!- 1.67°F 2 Channels +/- 2.65°F +/- l.91°F The above uncertainties include consideration of the uncertainty of all of the components included in the instrument loop which provides the indication.

The uncertainties on the average Pressurizer pressure and average RCS Tavg cited above reflect the uncertainties currently being used and may be revised in the future as a result of changes such as instrumentation replacements and increases in calibration intervals resulting from the transition to 24 month fuel cycles. Any future changes in uncertainties will be appropriately factored into the Pressurizer pressure and RCS Tavg limits in the COLR to ensure that the values used in the Safety Analyses remain bounding.

RAl-2 10 CFR 50.36{b) states in part, "the technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to § 50.34."

The application provided by the licensee did not state whether the safety analyses for the RCS pressure and temperature needed to be revised for the proposed amendment. The NRC staff requests that the licensee confirm if reanalysis was performed or if the current analysis remains bounding to support these new values for RCS pressure and temperature that are being relocated to the COLR for effects to the Updated Final Safety Analysis Report {UFSAR) Chapter 15 safety analyses.

DEP Response:

The administrative limits which account for the uncertainties in Pressurizer pressure and RCS Tavg are currently being utilized in the plant surveillance procedures to protect the current Technical Specification 3.4.1 Pressurizer Pressure limit of~ 2205 psig and the Tavg limit of s. 579.4°F.

Although the plant is able to operate within these limits, the operating margin to the Pressurizer pressure administrative limit is very small. In order to regain operating margin the Chapter 15 analyses were rerun to support a Pressurizer Pressure limit of~ 2195 psig using the NRC approved methods cited in RNP Technical Specification Section 5.6.5. It is RNP's intent to implement Pressurizer pressure limits in the COLR which utilize this new analysis value and account for instrumentation uncertainty.

No new analysis for RCS Tavg were required. The current analyses support an RCS Tavg of s.579.9°F which is slightly higher than the current Technical Specification RCS Tavg limit of s.575.4°F. It is RNP's intent to implement RCS Tavg limits which are based on the current analysis value of 579.9°F and account for instrumentation uncertainty.

U. S. Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0072 Page 4 of 9 RAl-3 TSTF-339 identifies WCAP-14483-A as the methodology that will be used to relocate TS parameters to COLR. WCAP-14483-A, Section 3.0, "Relocation of the OTDT and OPDT Setpoint Parameter Values to the COLA," provides the basis for Overtemperature /1 T {OTDT) and Overpower /1 T (OPDT) setpoints, including typical setpoint equations, and the basis for moving the OTDT and OPDT TS parameters to a COLR. WCAP-14483-A, Appendix 8, "Sample COLA Revisions," provides a sample COLA revision for reactor trip system instrumentation setpoints and departure from nucleate boiling parameters.

The licensee proposed to revise the TS Table 3.3.1-1, "Reactor Protection System Instruments," by relocating the numerical values of the Note 1 (Overtemperature /1 T) and Note 2 (Overpower /1 T) to the COLA and adding the notes. The proposed notes state The values denoted with [*] are specified in the COLR." However, the HBRSEP2 TS OTDT and OPDT equations differs from those in TSTF-339 and WCAP-14483-A and thus have somewhat different OTDT and OPDT TS parameters. Thus the sample COLA revision in WCAP-14483-A, Appendix B is not fully applicable to the proposed HBRSEP2 TS change. In addition, the licensee did not specify how the changes would appear in the proposed COLR. Therefore, the NRC staff requests that the license provide pages of the proposed COLA that show changes resulting from the LAR.

DEP Response:

See pages 5 - 9 of this Attachment.

U. S. Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0072 Page 5 of 9 ADDITIONAL CORE OPERATING LIMITS REPORT (COLR) PAGES (Note that these pages may be renumbered and reformatted when the final COLA is produced.)

U.S. Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0072 Page 6 of 9 ISl!la 00 tfOT OPERATI w IN THIS AAF.J.

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U.S. Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0072 Page 7 of 9 Overtemperature AT Setpoint Parameter Values Parameter Nominal Value Nominal Tavg at RTP T' .s 575.9 °F Nominal RCS Operating Pressure P' ~ 2235 psig Overtemperature I!!.T reactor trip setpoint K1 .S 1.1265 Overtemperature I!!. T reactor trip heatup setpoint penalty coefficient K 2 = 0.01228/°F Overtemperature I!!. T reactor trip depressurization setpoint penalty coefficient K 3 = 0.00089/psig Time constants utilized in the lead-lag compensator for Tavg r 1 ~ 20.08 sec

• 2 .S 3.08 sec f(/!!.I) "positive" breakpoint = 12%/!!.I f(/!!.I) "negative" breakpoint = -17%/!!.I f(/!!.I) "positive" slope =2.4%1!!.To/%1!!.I f(/!!.I) "negative" slope = 2.4%/!!.To/%1!!.I (referred to in Technical Specification 3.3.1)

U. S. Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0072 Page 8 of 9 Overpower AT Setpoint Parameter Values Parameter Nominal Value Nominal Tavg at RTP T' =:; 575.9 °P Overpower AT reactor trip setpoint Ki 5 1.06 Overpower AT reactor trip penalty Ks ~ 0.02/0 P for increasing T avg Ks ~ 0/ 0 P for decreasing Tavg Overpower AT reactor trip heatup setpoint penalty coefficient K6 ~ 0.00277 / 0 P when T > T' K6 ~ 0/0 P when T =:; T' Time constant utilized in the rate Jag compensator for AT 't 3 ~ 9 sec f(AI) "positive" breakpoint = 12%AI f(AD "negative" breakpoint =-17%AI f(AI) "positive" slope = 2.4%ATof%AI f(AI) "negative" slope = 2.4%ATof%AI (referred to in Technical Specification 3.3.1)

U. S. Nuclear Regulatory Commission Attachment to Serial: RNP-RA/16-0072 Page 9 of 9 Table 1 Reactor Coolant System DNB Parameters Parameter Indication No. Operable Limits Channels

1. Indicated RCS Average Temperature meter 3 ~ 577.63 °P meter 2 ~ 577.25 °P computer 3 ~ 578.23 °P computer 2 ~ 577.99 °P

2. Indicated Pressurizer Pressure meter 3 ~ 2215.78 psig meter 2 ~ 2220.46 psig computer 3 ~ 2209.41 psig computer 2 ~ 2212.65 psig

3. RCS Total Flow Rate ~ 99.8 x 106 lbm/hr (referred to in Technical Specification 3.4.1)