View source for RNP-RA/10-0029, Supplement to Request for Emergency Technical Specifications Change to Section 3.4.17, Chemical and Volume Control System

{{Adams
| number = ML100850104
| issue date = 03/24/2010
| title = Supplement to Request for Emergency Technical Specifications Change to Section 3.4.17, Chemical and Volume Control System
| author name = White B
| author affiliation = Progress Energy Carolinas, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000261
| license number = DPR-023
| contact person = 
| case reference number = RNP-RA/10-0029
| document type = Letter type:RNP
| page count = 12
}}

=Text=
{{#Wiki_filter:10 CFR 50.90 10 CFR 50.91(a)(5)
SProgress Energy Serial: RNP-RA/10-0029 MAR 2 .4 201 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 SUPPLEMENT TO REQUEST FOR EMERGENCY TECHNICAL SPECIFICATIONS CHANGE TO SECTION 3.4.17, CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS)
Ladies and Gentlemen:
By letters dated March 22 and March 23, 2010, and 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), submitted 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 3.4.17, "Chemical and Volume Control System, (CVCS)." The proposed change to TS 3.4.17 is related to the Required Actions and Completion Times associated with the loss of makeup water pathways from the Refueling Water Storage Tank (RWST) for Reactor Coolant Pump seal injection.
The proposed change is hereby being revised such that the proposed 72 hour completion time for one RWST pathway will be applicable on a temporary basis, which is proposed as the remainder of the current operating cycle.
Attachment I provides an Affirmation as required by 10 CFR 50.30(b).
Attachment II provides supplemental information for this revision to the proposed Technical Specifications change.
Attachment III provides a markup of the affected TS page. Attachment IV provides the retyped TS page.
Progress Energy Carolinas, Inc.
Robinson Nuclear Plant 3581 West Entrance Road Hartsville, SC 29550

United States Nuclear Regulatory Commission Serial: RNP-RA/10-0029 Page 2 of 2 Upon implementation of the Technical Specifications amendment, a corresponding revision to the TS Bases for Section 3.4.17 will be issued.
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 on an emergency basis to allow for a timely repair of a leak in the CVCS piping.
If you have any questions concerning this matter, please contact me at (843) 857-1253.
Sincerely, Be*iin C. White Manager - Support Services - Nuclear Attachments:
I. Affirmation II. Supplement to the Request for Emergency Technical Specifications Changes Related to Section 3.4.17, "Chemical and Volume Control System (CVCS)"
III. Markup of Technical Specifications Page IV. Retyped Technical Specifications Page BCW/cac c:      Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)
Mr. A. Gantt, Chief, Bureau of Radiological Health (SC)
Mr. L. A. Reyes, NRC, Region II Mr. T. Orf, NRC Project Manager, NRR NRC Resident Inspector, HBRSEP Attorney General (SC)

United States Nuclear Regulatory Commission Attachment Ito Serial: RNP-RA/1 0-0029 Page 1 of 1 AFFIRMATION The information contained in letter RNP-RA/10-0029 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.
r Executed On:     -) hcl/o Benjamin C. White Manager - Support Services - Nuclear HBRSEP, Unit No. 2

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/10-00029 Page 1 of 5 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 SUPPLEMENT TO THE REQUEST FOR EMERGENCY TECHNICAL SPECIFICATIONS CHANGE RELATED TO SECTION 3.4.17. "CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS)"
By letters dated March 22 and March 23, 2010, and 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), submitted 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 change as described in the March 23, 2010, letter is hereby being revised, such that the proposed 72 hour completion time for one RWST pathway will be applicable on a temporary basis, which is proposed as the remainder of the current operating cycle.
A revised description of the proposed change is provided as follows:
A footnote is being added to allow the Completion Time for Condition B, Required Action B. 1 to be 72 hours for the remainder of the current operating cycle, which is Operating Cycle 26. The footnote will specifically state:
The Completion Time for Required Action B. 1 to Restore Makeup Water Pathway from the RWST to OPERABLE status is allowed to be 72 hours during Operating Cycle 26.
Operating Cycle 26 is currently scheduled to end on or about April 17, 2010, which is the currently planned date to start the next refueling outage.
The justification of the proposed change, justification for an emergency amendment, No Significant Hazards Consideration Determination, and Environmental Impact Consideration, as provided by letter dated March 23, 2010, are considered to remain applicable for this revision to the proposed change. The shorter duration of applicability of this change does not affect the justifications as previously provided because a temporary change to the completion time is not significantly different from a permanent change to the completion time.
Additionally, it was recently determined that the pipe flaw analysis performed to evaluate operability of this line included a conservative error. It is expected that the previously stated calculated limit of 1.79 inches will be revised. This does not impact the need for this change on an emergency basis because the leak repair is necessary and the leak repair is estimated to exceed the current Technical Specifications completion time of 24 hours for one RWST pathway inoperable.
As requested, a copy of the Technical Requirements Manual Section 3.6 and associated bases is provided for information, as follows:

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/10-00029 Page 2 of 5 CVCS - Boric Acid and Primary Water Storage Tank 3.6 3.6   CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS)    - BORIC ACID AND PRIMARY WATER STORAGE TANK TRMS 3.6           The following portions of the CVCS shall be OPERABLE:
(CTS 3.2.2.b.
c, e, and f)       a. Both boric acid transfer pumps;
: b. The boric acid tanks together containing a total minimum volume of 3080 gallons of 20,000 ppm to 22.500 ppm boron solution at temperature of t 145 0 F:
: c. Two channels of heat tracing for the flow path from the boric acid tanks: and
: d. The Primary Water Storage Tank containing a 30.000 gallons of water.
APPLICABILITY:     MODES 1, 2, 3. and 4.
CONPENSATORY MEASURES CONDITION           REQUIRED COMPENSATORY MEASURE     COMPLETION TIME A. One boric acid             A.1      Restore boric acid       72 hours transfer pump                      transfer pump to inoperable.                       OPERABLE status.
B. One channel of heat        B.1      Restore one channel      72 hours tracing inoperable,                of heat tracing to OPERABLE status.
(continued)
HBRSEP Unit No. 2                      3.6-1                       PLP-100 Rev. 10

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/10-00029 Page 3 of 5 CVCS  -Boric Acid and Primary Water Storage Tank 3.6 COMPENSATORY MEASURFS (conti                                  _ud)
CONDITION           REQUIRED COMPENSATORY MEASURE  COMPLETION TIME C. Required Compensatory    C.1 Initiate action to restore   Immediately Measure and                  inoperable component to associated Completion        OPERABLE Status.
Time of Condition A or B not met.              AND C.2 Initiate a Condition         Immediately Report in accordance with the Corrective Action Program.
AND C.3 Identify any compensatory   7 days action to be taken while the inoperability of the pump and/or heat tracing channel persists.
D. Requirements of TRMS      D.1 Initiate action to restore   Immediately not met for reasons          boric acid addition other than Conditions        capability to the RCS A or B.                      from the Boric Acid Tank.
AND D.2 Initiate a Condition Report in accordance with  Immediately the Corrective Action Program.
AND D.3 Identify any compensatory   7 days action to be taken while the inoperability persists.
HBRSEP Unit No. 2                      3.6-2                       PLP-100 Rev. 10

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/10-00029 Page 4 of 5 CVCS - Boric Acid and Primary Water Storage Tank 3.6 T'qT RrI:'ITRPMIHM' Y
TEST                                    FREQUENCY 4
TR 3.6.1           Perform boron concentration analysis          ----- NOTES---
(CTS Table         of boric acid tank sample.                    1. The maximum 4.1.2 item 4)                                                          time between tests may be 5 days.
: 2. TR 3.0.2 is not applicable.
2 days per week J ____________________________________________
HBRSEP Unit No. 2                       3.6-3                         PLP-100 Rev. 10

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/10-00029 Page 5 of 5 CVCS - Boric Acid and Primary Water Storage Tank B 3.6 B 3.6 CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS)    - BORIC ACID AND PRIMARY WATER STORAGE TANK BASES The Chemical and Volume Control System provides control of the Reactor Coolant System boron inventory. This is normally accomplished by using either one of the three charging pumps in series with one of the two boric acid pumps.
The boric acid transfer pumps can deliver the boric acid tank contents (concentration of boric acid) to the charging pumps.
The quantity of boric acid in storage from the boric acid tanks is sufficient and fast enough to borate the reactor to cold shutdown at any time during core life. Thus. the out of service interval for the boric acid pumps is considered conservative since borated water is also available from the refueling water storage tank via the charging pumps. Approximately 2640 gallons of the 20,000 to 22.500 ppm boron solution are required to meet MODE 5 conditions. Thus a minimum of 3080 gallons in the boric acid tanks is specified. An upper concentration limit of 13% boric acid (22,500 ppm) in the tank is specified to maintain solution solubility at the specified low temperature limit of 1450F. Two channels of heat tracing are installed on lines normally containing concentrated boric acid solution to maintain the specified low temperature limit. The plant operating procedures require immediate action to affect repairs of an inoperable component: therefore, in most cases repairs will be completed in less than the specified repair time.
When borating to MODE 5 conditions using boric acid from the boric acid tanks.
make up water must be supplied to compensate for shrinkage of the reactor coolant. Sufficient water for this purpose must be maintained in the primary water storage tank.
The overall reliability of the Chemical and Volume Control System is improved by its normal mode of operation, i.e.. at least one charging pump, one boric acid transfer pump and one boric acid tank are in continuous operation.
In the event that the pathways for boric acid from the boric acid tanks to the Reactor Coolant System are unavailable, the Refueling Water Storage Tank provides an alternate means to shut down the plant.
HBRSEP Unit No. 2                   B 3.6-1                      PLP-100 Rev. 2

United States Nuclear Regulatory Commission Attachment III to Serial: RNP-RA/1 0-0029 2 Pages (including cover page)
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE RELATED TO THE CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS)
MARKUP OF TECHNICAL SPECIFICATIONS PAGE

CVCS 3.4.17 3.4     REACTOR COOLANT SYSTEM (RCS) 3.4.17 Chemical and Volume Control System (CVCS)
LCO     3.4.17                Reactor Coolant Pump (RCP)                             seal injection shall be OPERABLE, with:
: a.        Two charging pumps shall be OPERABLE; and
: b.        Two Makeup Water Pathways from the Refueling Water Storage Tank (RWST) shall be OPERABLE.
APPLICABILITY:                MODES 1, 2, 3, and 4 ACTIONS CONDITION                                          REQUIRED ACTION                                          COMPLETION TIME A.         One required                             A.1         Restore required                                          24 hours charging pump                                         charging pump to inoperable.                                          OPERABLE status.
B.         One Makeup Water                         B.1         Restore Makeup Water                                      24 hours*
Pathway from the                                      Pathway from the RWST RWST inoperable,                                     to OPERABLE status.
C.         Required Action and                      C.1         Be in MODE 3.                                             6 hours associated Completion Time of                       AND               B Condition A or B not met.                                 C.2                 in MODE 5.                                        36 hours (continued)
     <INSERT FOOTNOTE -
* The Completion Time for Required Action B.1 to Restore Makeup Water Pathway from the RWST to OPERABLE status is allowed to be 72 hours during Operating Cycle 26.
    - - -  .- .- .- .- .- .- .-   .- .- .- .- .- .- .-  .- r..
I HBRSEP Unit No. 2                                                 3.4-49                                                   Amendment No. 476

United States Nuclear Regulatory Commission Attachment IV to Serial: RNP-RA/1 0-0029 2 Pages (including cover page)
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE RELATED TO THE CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS)
RETYPED TECHNICAL SPECIFICATIONS PAGE

CVCS 3.4.17 3.4   REACTOR COOLANT SYSTEM (RCS) 3.4.17 Chemical and Volume Control System (CVCS)
LCO   3.4.17       Reactor Coolant Pump (RCP)   seal injection shall be OPERABLE, with:
: c. Two charging pumps shall be OPERABLE; and
: d. Two Makeup Water Pathways from the Refueling Water Storage Tank (RWST) shall be OPERABLE.
APPLICABILITY:     MODES 1, 2, 3, and 4 ACTIONS CONDITION                    REQUIRED ACTION           COMPLETION TIME A.      One required           A.1    Restore required          24 hours charging pump                  charging pump to inoperable.                    OPERABLE status.
B.      One Makeup Water Pathway from the B.1    Restore Makeup Water Pathway from the RWST 24 hours*          I RWST inoperable,              to OPERABLE status.
C.      Required Action and    C.1    Be in MODE 3.             6 hours associated Completion Time of     AND Condition A or B not met.               C.2    Be in MODE 5.             36 hours (continued)
* The Completion Time for Required Action B.1 to Restore Makeup Water Pathway from the RWST to OPERABLE status is allowed to be 72 hours during Operating Cycle 26.
HBRSEP Unit No. 2                      3.4-49                     Amendment No.}}