ML071540001

H.B. Robinson - License Amendment 216 to Adopt Technical Specifications Task Force (TSTF) Standard TS Change Traveler, TSTF-447, Using the Consolidated Line Item Improvement Process

ML071540001
Person / Time
Site:	Robinson
Issue date:	07/16/2007
From:	Regner L M NRC/NRR/ADRO/DORL/LPLII-2
To:	Walt T D Carolina Power & Light Co
REGNER, Lisa, DORL/LPL2-2, 415-1906
Shared Package
ML071540002	List: ML071540001 ML072010236
References
TAC MD4250
Download: ML071540001 (9)

Text

July 16, 2007Mr. Thomas D. Walt, Vice PresidentH. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550-0790

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OFAMENDMENT TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) STANDARD TS CHANGE TRAVELER, TSTF-447, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MD4250)

Dear Mr. Walt:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 216 to FacilityOperating License No. DPR-23 for the H.B. Robinson Steam Electric Plant, Unit No. 2 (HBR).

This amendment consists of changes to the TSs in response to your application dated February 2, 2007. The amendment adopts the TSTF-447, Elimination of Hydrogen Recombiners and Change toHydrogen and Oxygen Monitors, which deletes the TS requirements related to containmenthydrogen monitors and supports implementation of the revisions of 10 CFR 50.44, CombustibleGas Control for Nuclear Power Reactors, that became effective on October 16, 2003. A copy of our related safety evaluation is also enclosed. The Notice of Issuance will beincluded in the Commission's next biweekly Federal Register notice. Sincerely,/RA/Lisa M. Regner, Project ManagerPlant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-261

Enclosures:

1. Amendment No. 216 to DPR-232. Safety Evaluationcc w/encls: See next page Mr. T. D. WaltH. B. Robinson Steam Electric Plant,Carolina Power & Light Company Unit No. 2 cc:

David T. ConleyAssociate General Counsel II - Legal Department Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, North Carolina 27602-1551Ms. Margaret A. ForceAssistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602U. S. Nuclear Regulatory CommissionResident Inspector's Office H. B. Robinson Steam Electric Plant 2112 Old Camden Road Hartsville, South Carolina 29550Mr. Ernest J. Kapopoulos, Jr.Plant General Manager H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550Director of Site OperationsH. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550Public Service CommissionState of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211Ms. J. F. LucasManager - Support Services - Nuclear H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550Mr. C. T. BaucomSupervisor, Licensing/Regulatory Programs H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550Ms. Beverly Hall, Section ChiefN.C. Department of Environment and Natural Resources Division of Radiation Protection 3825 Barrett Dr.

Raleigh, North Carolina 27609-7721Mr. Robert P. GruberExecutive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, North Carolina 27699-4326Mr. Henry H. Porter, Assistant DirectorSouth Carolina Department of Health Bureau of Land & Waste Management 2600 Bull Street Columbia, South Carolina 29201Mr. J. Paul FulfordManager, Performance Evaluation and Regulatory Affairs PEB 5 Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602-1551Mr. John H. O'Neill, Jr.Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street NW.

Washington, DC 20037-1128

Pkg ML071540002 Amendment ML071540001TS ML072010236*No significant change from SE InputMemoOFFICELPL2-2/PMLPL2-2/PMLPL2-2/LAITSB/BCLPL2-2/BCNAMELRegnerSBaileyCSolaTKobetz*BMozafari for TBoyce DATE7/3/077/16/077/3/073/21/077/16/07 CAROLINA POWER & LIGHT COMPANYDOCKET NO. 50-261H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 216Renewed License No. DPR-231.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Carolina Power & Light Company (thelicensee), dated July 17, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations(10 CFR) Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (I) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications, asindicated in the attachment to this license amendment; and paragraph 3.B. of Renewed Facility Operating License No. DPR-23 is hereby amended to read as follows:B. Technical SpecificationsThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 216, are hereby incorporated in the license.The licensee shall operate the facility in accordance with the Technical Specifications. 3.This license amendment is effective as of the date of its issuance and shall beimplemented within 60 days.FOR THE NUCLEAR REGULATORY COMMISSION/RA/ Brenda Mozafari for Thomas H. Boyce Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Operating License No. DPR-23 and the Technical SpecificationsDate of Issuance: July 16, 2007 ATTACHMENT TO LICENSE AMENDMENT NO. 216RENEWED FACILITY OPERATING LICENSE NO. DPR-23DOCKET NO. 50-261Replace page 3 of Operating License No. DPR-23 with the attached page 3.Replace the following pages of the Appendix A Technical Specifications with the attachedrevised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.Remove PageInsert Pages3.3-303.3-303.3-313.3-31 3.3-323.3-32 July 16, 2007SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 216 TORENEWED FACILITY OPERATING LICENSE NO. DPR-23CAROLINA POWER & LIGHT COMPANYH. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2DOCKET NO. 50-26

11.0 INTRODUCTION

By application to the Nuclear Regulatory Commission (NRC, Commission) datedFebruary 2, 2007, Carolina Power and Light Company (CP&L, the licensee), requested a change to the technical specifications (TS) for the H.B. Robinson Steam Electric Plant, Unit 2(HBR). The proposed change would delete the TS requirements associated with containment hydrogen monitors.The NRC has revised Title 10 to the Code of Federal Regulations (10 CFR), Section 50.44,Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors. Theamended standards eliminated the requirements for hydrogen recombiners and relaxed the requirements for hydrogen and oxygen monitoring. In letters dated December 17, 2002, and May 12, 2003, the Nuclear Energy Institute (NEI) Technical Specifications Task Force (TSTF) proposed to remove requirements for hydrogen recombiners and hydrogen and oxygen monitors from the standard technical specifications (STS) (NUREGs 1430 - 1434) on behalf of the industry. This proposed change was designated TSTF-447. Hydrogen purge systems are not part of the STS, however, the Commission eliminated the hydrogen release associated with a design-basis loss of coolant accident (LOCA) from 10 CFR 50.44 and the associated requirements that necessitated the need for the backup hydrogen vent and purge systems. The NRC staff prepared this model safety evaluation (SE) for the elimination of requirementsregarding containment hydrogen recombiners and the removal of requirements from TS for containment hydrogen and oxygen monitors and solicited public comment (67 FR 50374, August 2, 2002) in accordance with the Consolidated Line Item Improvement Process (CLIIP).

The use of the CLIIP in this matter is intended to help the NRC to efficiently process amendments that propose to remove the hydrogen recombiner and hydrogen and oxygen monitor requirements from TS. Licensees of nuclear power reactors to which this model applies were informed (68 FR 55416, September 25, 2003) that they could request amendments conforming to the model, and, in such requests, should confirm the applicability of this SE to their reactors and provide the requested plant-specific verifications and

commitments. 2.0 BACKGROUNDRegulatory Issue Summary 2000-06, Consolidated Line Item Improvement Process forAdopting Standard Technical Specification Changes for Power Reactors, was issued onMarch 20, 2000. The CLIIP is intended to improve the efficiency of NRC licensing processes.

This is accomplished by processing proposed changes to the STS in a manner that supports subsequent license amendment applications. The CLIIP includes an opportunity for the public to comment on proposed changes to the STS following a preliminary assessment by the NRC staff and finding that the change will likely be offered for adoption by licensees. The NRC staff evaluates any comments received for a proposed change to the STS and either reconsiders the change or proceeds with announcing the availability of the change for proposed adoption by licensees. Those licensees opting to apply for the subject change to TS are responsible forreviewing the staff's evaluation, referencing the applicable technical justifications, and providing any necessary plant-specific information. Each amendment application made in response to the notice of availability would be processed and noticed in accordance with applicable rules and NRC procedures.The Commission's regulatory requirements related to the content of TS are set forth in10 CFR 50.36. This regulation requires that the TS include items in five specific categories.

These categories include (1) safety limits, limiting safety system settings and limiting control settings, (2) limiting conditions for operation (LCO), (3) surveillance requirements, (4) design features, and (5) administrative controls. However, the regulation does not specify the particular TSs to be included in a plant's license.Additionally, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether anLCO is required to be included in the TS. These criteria are as follows:1.Installed instrumentation that is used to detect, and indicate in the control room,a significant abnormal degradation of the reactor coolant pressure boundary.2.A process variable, design feature, or operating restriction that is an initialcondition of a design-basis accident or transient analysis that assumes either the failure of or presents a challenge to the integrity of a fission product barrier. 3.A structure, system, or component that is part of the primary success path andwhich functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.4.A structure, system or component which operating experience or probabilisticrisk assessment has shown to be significant to public health and safety.Existing LCOs and related surveillances included as TS requirements which satisfy any of thecriteria stated above must be retained in the TS. Those TS requirements which do not satisfy these criteria may be relocated to other licensee-controlled documents.As part of the rulemaking that revised 10 CFR 50.44, the Commission retained requirements forensuring a mixed atmosphere, inerting Mark I and II containments, and providing hydrogen control systems capable of accommodating an amount of hydrogen generated from ametal-water reaction involving 75 percent of the fuel cladding surrounding the active fuel region in Mark III and ice condenser containments. The Commission eliminated the design-basisLOCA hydrogen release from 10 CFR 50.44 and consolidated the requirements for hydrogen and oxygen monitoring to 10 CFR 50.44 while relaxing safety classifications and licensee commitments to certain design and qualification criteria. The Commission also relocated without change the hydrogen control requirements in 10 CFR 50.34(f) to 10 CFR 50.44 and the high point vent requirements from 10 CFR 50.44 to 10 CFR 50.46a.3.0 EVALUATIONThe ways in which the requirements and recommendations for combustible gas control wereincorporated into the licensing bases of commercial nuclear power plants varied as a function of when plants were licensed. Plants that were operating at the time of the Three Mile Island (TMI), Unit 2, accident are likely to have been the subject of confirmatory orders that imposed the combustible gas control functions described in NUREG-0737, Clarification of TMI ActionPlan Requirements, as obligations. The issuance of plant-specific amendments adopting thechanges of TSTF-447 to remove hydrogen recombiner and hydrogen and oxygen monitoring controls from TS supersede the combustible gas control specific requirements imposed by post-TMI confirmatory orders. 3.1 Hydrogen Monitoring EquipmentSection 50.44(b)(1), the STS, and plant-specific TS currently contain requirements formonitoring hydrogen. Licensees have also made commitments to design and qualification criteria for hydrogen monitors in Item II.F.1, Attachment 6 of NUREG-0737 and RegulatoryGuide (RG) 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plantand Environs Conditions During and Following an Accident. The hydrogen monitors arerequired to assess the degree of core damage during a beyond design-basis accident and confirm that random or deliberate ignition has taken place. If an explosive mixture that could threaten containment integrity exists during a beyond design-basis accident, then other severe accident management strategies, such as purging and/or venting, would need to be considered.

The hydrogen monitors are needed to implement these severe accident management strategies.With the elimination of the design-basis LOCA hydrogen release, hydrogen monitors are nolonger required to mitigate design-basis accidents and, therefore, the hydrogen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 recommends classifying the hydrogen monitors as Category 1. RG 1.97 Category 1 is intended for key variables that most directly indicate the accomplishment of a safety function for design-basis accident events and, therefore, are items usually addressed within TS. As part of the rulemaking to revise 10 CFR 50.44, the Commission found that the hydrogen monitors no longer meet the definition of Category 1 in RG 1.97. The Commission concluded that Category 3, as defined in RG 1.97, is an appropriate categorization for the hydrogen monitors because the monitors are required to diagnose the course of beyond design-basis accidents.

Hydrogen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary. Section 4 of Attachment 2 to SECY-00-0198, StatusReport on Study of Risk-Informed Changes to the Technical Requirements of 10 CFR Part 50 (Option 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.44 (Combustible Gas Control), found that the hydrogen monitors were not risk-significant. Therefore, the NRCstaff finds that hydrogen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in TS and, therefore, may be relocated to other licensee-controlled documents.However, because the monitors are required to diagnose the course of beyond design-basisaccidents, each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond design-basis accidents.The elimination of Post-Accident Sampling System requirements from some plant-specific TS(and associated CLIIP notices) indicated that during the early phases of an accident, safety-grade hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration. The NRC staff has subsequently concluded that Category 3 hydrogen monitors also provide an adequate capability for monitoring containment hydrogen concentration during the early phases of an accident.4.0 VERIFICATIONS AND COMMITMENTSAs requested by the NRC staff in the notice of availability for this TS improvement, the licenseehas addressed the following plant-specific verifications and commitments.4.1Each licensee should verify that it has, and make a regulatory commitment tomaintain, a hydrogen monitoring system capable of diagnosing beyond design-basis accidents.The licensee has verified that it has a hydrogen monitoring system capable of diagnosingbeyond design-basis accidents. The licensee has committed in its application to maintain the hydrogen monitors within its Updated Final Safety Analysis Report. The licensee will implement this commitment as part of the implementation of the amendment.4.2For plant designs with an inerted containment, each licensee should verify that ithas, and make a regulatory commitment to maintain, an oxygen monitoring system capable of verifying the status of the inert containment.This is not applicable as the licensee does not have an inerted containment.The NRC staff finds that reasonable controls for the implementation and for subsequentevaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensee's administrative processes, including its commitment management program.

The NRC staff has determined that the commitments do not warrant the creation of regulatory requirements which would require prior NRC approval of subsequent changes. The NRC staff has agreed that NEI 99-04, Revision 0, Guidelines for Managing NRC Commitment Changes

,provides reasonable guidance for the control of regulatory commitments made to the NRC staff (see Regulatory Issue Summary 2000-17, Managing Regulatory Commitments Made by PowerReactor Licensees to the NRC Staff, dated September 21, 2000). The commitments should becontrolled in accordance with the industry guidance or comparable criteria employed by a specific licensee. The NRC staff may choose to verify the implementation and maintenance of these commitments in a future inspection or audit.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the South Carolina State official was notifiedof the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

This amendment changes requirements with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed findingthat the amendment involves no significant hazards consideration and there has been no public comment on such finding (72 FR 20378, April 24, 2007). Accordingly, the amendment 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 need be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) thereis reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributor: Trent Wertz Date: July 16, 2007