RNP-RA/07-0073, Request for Administrative Changes to the Operating License and Technical Specifications

Request for Administrative Changes to the Operating License and Technical Specifications

ML073320195
Person / Time
Site:	Robinson
Issue date:	11/19/2007
From:	Baucom C Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/07-0073
Download: ML073320195 (27)

Text

10 CFR 50.90 Serial: RNP-RA/07-0073 Nov 19, 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 ADMINISTRATIVE CHANGES TO THE OPERATING LICENSE AND TECHNICAL SPECIFICATIONS 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 Operating License and 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 changes make administrative improvements to various Operating License and Technical Specifications sections as listed in Attachment II.

Attachment I provides an Affirmation as required by 10 CFR 50.30(b).

Attachment II provides a description of the current conditions and proposed changes, technical justification for 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 a retyped version of the affected TS pages.

In accordance with 10 CFR 50.91(b), a copy of this license amendment request is being provided to the State of South Carolina.

Nuclear Regulatory Commission approval of the proposed license amendment by August 27, 2008, is requested, with a 30 day implementation period.

United States Nuclear Regulatory Commission Serial: RNP-RA/07-0073 Page 2 of 2 If you have any questions concerning this matter, please contact me at (843) 857-1253.

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

I. Affirmation II. Request for Administrative Changes to the Operating License and Technical Specifications III. Markup of Operating License and Technical Specifications Pages IV. Retyped Operating License and Technical Specifications Pages RAC/rac 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. Vaaler, NRC, NRR NRC Resident Inspector, HBRSEP Attorney General (SC)

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/07-0073 Page 1 of 1 AFFIRMATION The information contained in letter RNP-RA/07-0073 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: _16 Nov 2007______ _Original signed by T. D. Walt__

T. D. Walt Vice President, HBRSEP, Unit No. 2

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0073 Page 1 of 4 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR ADMINISTRATIVE CHANGES TO THE OPERATING LICENSE AND TECHNICAL SPECIFICATIONS Description of Current Conditions, Proposed Changes, and Technical Justification The proposed changes are to the following sections of the H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, Operating License (OL) and Technical Specifications (TS):

1. OL Section 3.G (1): The secondary water chemistry program requirements specified in this section are redundant to the requirements of TS 5.5.10, Secondary Water Chemistry Program. Therefore, this condition is being deleted from the OL, as it is appropriately addressed as a TS program.

2. OL Section 3.G (2): The leakage reduction program requirements specified in this section are redundant to the requirements of TS 5.5.2, Primary Coolant Sources Outside Containment. Therefore, this condition is being deleted from the OL, as it is appropriately addressed as a TS program.

3. TS Section 1.1, Definitions: In the last line of the definition for SHUTDOWN MARGIN, the word the prior to 547°F is being deleted. This is a grammar change.

4. TS Section 3.1.7, Rod Position Indication: The footnote at the bottom of Page 3.1-15 was only applicable during Cycle 22. HBRSEP, Unit No. 2, is now in operating Cycle 25.

Therefore, the footnote is obsolete and is being deleted.

5. TS Section 3.4.3, RCS Pressure and Temperature (P/T) Limits - Figure 3.4.3-1 and Figure 3.4.3-2: When these figures were issued in Amendment No. 202 (NRC letter dated February 7, 2005 -TAC NO. MC4160), some information that was on the proposed figures (Progress Energy letter dated August 19, 2004) was inadvertently omitted or typed incorrectly.

Specifically, in Figure 3.4.3-1, in the notes at the top, the Upper Shell Plate Weld ID (W10201-1) was omitted and the words allowance and instrumentation were typed with an uppercase A or I instead of lower case. In Figure 3.4.3-2, in the notes at the top, the Upper Shell Plate Weld ID (W10201-1) and the Girth Weld ID (10-273) were omitted, the limiting ART Values for 3/4T of 147°F and 172°F were omitted, and the words allowance and instrumentation were typed with an uppercase A or I instead of lower case.

Additionally, in the graph, the identifier for the 60°F/Hr curve is missing the Hr term.

These errors are being corrected.

6. TS Section 3.4.9, Pressurizer: For Condition B, the symbol is being replaced with a <

symbol. The current symbol is incorrect based on the LCO requirements that specify that a pressurizer heater capacity equal to or greater than 125 kW is acceptable.

7. TS Section 3.7.4, Auxiliary Feedwater (AFW) System: On the top of the table, the words Actions (continued) are being added and in Condition E, the term OR is being moved to the right to line up properly with the text consistent with Standard TS format. These are formatting changes.

8. TS Section 5.5.12, Explosive Gas and Storage Tank Radioactivity Monitoring Program:

The HBRSEP, Unit No. 2, design is such that the concentration of oxygen in the Waste Gas

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0073 Page 2 of 4 Decay Tanks is controlled to be below the concentration at which a hydrogen explosion could occur, regardless of the hydrogen concentration. Therefore, by controlling the oxygen concentration to below limits, the combination of oxygen and hydrogen in the system will not be an explosive mixture. The current TS wording can imply there are limits for both hydrogen and oxygen. The term hydrogen and is being deleted for clarity.

These changes are administrative and are intended to ensure the TS are accurate and up-to-date.

There will be no changes to the plant design or to the procedural controls for the operation, surveillance, or maintenance of the plant as a result of the proposed changes.

No Significant Hazards Consideration Determination Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc., is proposing changes to the Operating License and 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 changes are administrative as they delete requirements that are obsolete or redundant, or correct and clarify the typing and formatting of other requirements. The proposed changes will not result in changes to the plant design or the procedural controls for the operation, surveillance, or maintenance of the plant.

An evaluation of the proposed changes 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:

1. Do the Proposed Changes Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated?

No. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed changes are administrative. The changes delete obsolete or redundant requirements, clarify existing requirements, and correct typing and formatting errors. There will be no resulting changes to the plant design or procedural controls. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the Proposed Changes Create the Possibility of a New or Different Kind of Accident From Any Previously Evaluated?

No. The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated. There are no physical changes being made to the plant or to the manner in which the plant is operated. Therefore, the changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the Proposed Changes Involve a Significant Reduction in the Margin of Safety?

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0073 Page 3 of 4 No. The proposed changes do not involve a significant reduction in the margin of safety.

There are no physical changes being made to the plant or to the manner in which the plant is operated. The proposed changes are administrative. The changes delete obsolete or redundant requirements, clarify existing requirements, and correct typing and formatting errors. Therefore, the changes do not involve a significant reduction in any margin of safety for HBRSEP, Unit No. 2.

Based on the preceding discussion, it has been determined that the requested changes do 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 has reviewed this request and determined that 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., is proposing changes to the Operating License and 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 changes are administrative as they delete requirements that are obsolete or redundant, or correct and clarify the typing and formatting of other requirements. The proposed changes will not result in changes to the plant design or the procedural controls for the operation, surveillance, or maintenance of the plant.

Basis The proposed changes meet 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 changes do not involve a significant hazards consideration.

2. The proposed changes will not result in changes to the plant design or the procedural controls for the operation, surveillance, or maintenance of the plant. The proposed changes do not affect the generation or control of effluents. Therefore, the proposed changes will not

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/07-0073 Page 4 of 4 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 changes will not cause a significant increase in occupational radiation exposure. There are no proposed physical changes to the facility or to the manner in which the facility is operated. Therefore, the proposed changes will not result in a significant increase in individual or cumulative occupational radiation exposure.

United States Nuclear Regulatory Commission Attachment III to Serial: RNP-RA/07-0073 10 Pages (including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR ADMINISTRATIVE CHANGES TO THE OPERATING LICENSE AND TECHNICAL SPECIFICATIONS MARKUP OF OPERATING LICENSE AND TECHNICAL SPECIFICATIONS PAGES

Definitions 1.1 1.1 Definitions

SHUTDOWN MARGIN a. All rod cluster control assemblies (RCCAs) are (continued) fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and

b. In MODES 1 and 2, the fuel and moderator temperatures are changed to the 547oF.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing each slave relay and verifying the OPERABILITY of each slave relay. The SLAVE RELAY TEST shall include, as a minimum, a continuity check of associated testable actuation devices.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

TRIP ACTUATING DEVICE A TADOT shall consist of operating the trip OPERATIONAL TEST actuating device and verifying the OPERABILITY of (TADOT) required alarm, interlock, display, and trip functions. The TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the required accuracy.

HBRSEP Unit No. 2 1.1-5 Amendment No. 176

AFW System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 for Condition A AND or B not met.

C.2 Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> D. Steam driven AFW pump D.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 /> or flow path inoperable in MODE 1, AND 2, or 3.

D.2 Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> AND One motor driven AFW pump or flow path inoperable in MODE 1, 2, or 3.

E. Four AFW flow paths E.1 ---------NOTE--------

inoperable in MODE 1, LCO 3.0.3 and all 2, or 3. other LCO Required Actions requiring OR OR MODE changes are suspended until Three AFW pumps one AFW pump and flow inoperable in MODE 1, path are restored to 2, or 3. OPERABLE status.

Initiate action to Immediately restore one AFW pump and flow path to OPERABLE status.

F. Required AFW pump and F.1 Initiate action to Immediately flow path inoperable restore AFW pump and in MODE 4. flow path to OPERABLE status.

HBRSEP Unit No. 2 3.7-11 Amendment No. 176

United States Nuclear Regulatory Commission Attachment IV to Serial: RNP-RA/07-0073 10 Pages (including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REQUEST FOR ADMINISTRATIVE CHANGES TO THE OPERATING LICENSE AND TECHNICAL SPECIFICATIONS RETYPED OPERATING LICENSE AND TECHNICAL SPECIFICATIONS PAGES

Definitions 1.1 1.1 Definitions

SHUTDOWN MARGIN a. All rod cluster control assemblies (RCCAs) are (continued) fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and

b. In MODES 1 and 2, the fuel and moderator temperatures are changed to 547oF.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing each slave relay and verifying the OPERABILITY of each slave relay. The SLAVE RELAY TEST shall include, as a minimum, a continuity check of associated testable actuation devices.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

TRIP ACTUATING DEVICE A TADOT shall consist of operating the trip OPERATIONAL TEST actuating device and verifying the OPERABILITY of (TADOT) required alarm, interlock, display, and trip functions. The TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the required accuracy.

HBRSEP Unit No. 2 1.1-5 Amendment No.

Rod Position Indication 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Rod Position Indication LCO 3.1.7 The Analog Rod Position Indication (ARPI) System and the Demand Position Indication System shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

---

NOTE-------------------------------------

Separate Condition entry is allowed for each inoperable rod position indicator per group and each demand position indicator per bank.

CONDITION REQUIRED ACTION COMPLETION TIME A. One ARPI per group inoperable for one or A.1 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 /> more groups. of the rods with inoperable position indicators by using movable incore detectors.

OR A.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.

B. One or more rods with B.1 Verify the position 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> inoperable position of the rods with indicators have been inoperable position moved in excess of indicators by using 24 steps in one movable incore direction since the detectors.

last determination of the rod's position. OR (continued)

HBRSEP Unit No. 2 3.1-15 Amendment No.

Pressurizer 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Pressurizer LCO 3.4.9 The pressurizer shall be OPERABLE with:

a. Pressurizer water level # 63.3% in MODE 1;

b. Pressurizer water level # 92% in MODES 2 and 3; and

c. Pressurizer heaters OPERABLE with a capacity of $ 125 kW and capable of being powered from an emergency power supply.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressurizer water A.1 Be in MODE 3 with 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> level not within reactor trip breakers limit. open.

AND A.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> B. Capacity of required B.1 Restore required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> pressurizer heaters pressurizer heaters

< 125 kW. to OPERABLE status.

C. Required pressurizer C.1 Restore capability to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

heaters not capable of power the required being powered from an pressurizer heaters emergency power from an emergency supply. power supply.

(continued)

HBRSEP Unit No. 2 3.4-21 Amendment No.

AFW System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 for Condition A AND or B not met.

C.2 Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> D. Steam driven AFW pump D.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 /> or flow path inoperable in MODE 1, AND 2, or 3.

D.2 Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> AND One motor driven AFW pump or flow path inoperable in MODE 1, 2, or 3.

E. Four AFW flow paths E.1 ---------NOTE--------

inoperable in MODE 1, LCO 3.0.3 and all 2, or 3. other LCO Required Actions requiring OR MODE changes are suspended until Three AFW pumps one AFW pump and flow inoperable in MODE 1, path are restored to 2, or 3. OPERABLE status.

Initiate action to Immediately restore one AFW pump and flow path to OPERABLE status.

F. Required AFW pump and F.1 Initiate action to Immediately flow path inoperable restore AFW pump and in MODE 4. flow path to OPERABLE status.

HBRSEP Unit No. 2 3.7-11 Amendment No.