ML062210509

Issuance of Amendment and Partial Denial Reactor Protection System and Engineered Safety Feature Actuation System Instrumentation Tables

ML062210509
Person / Time
Site:	Robinson
Issue date:	09/22/2006
From:	Patel C P NRC/NRR/ADRO/DORL/LPLII-2
To:	Walt T D Carolina Power & Light Co
Mozafari B L, NRR/ADRO/DORL, 415-2020
References
TAC MC4219
Download: ML062210509 (13)

Text

September 22, 2006Mr. Thomas D. Walt, Vice PresidentCarolina Power & Light Company H. B. Robinson Steam Electric Plant Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OFAMENDMENT AND PARTIAL DENIAL REGARDING REACTOR PROTECTION SYSTEM AND ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TABLES (TAC NO. MC4219)

Dear Mr. Walt:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 210 to RenewedFacility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2.

This amendment is in response to your application dated August 20, 2004, as supplemented byletters dated June 22, 2005, June 26, 2006, and September 18, 2006.The amendment approves the revised Technical Specifications Allowable Values for threereactor protection system instrumentation functions. The request for changes in two functions,specifically reactor coolant system flow-low and high steam flow in two steam lines coincidentwith steam line pressure-low, was withdrawn.A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in theCommission's biweekly Federal Register notice.Sincerely, /RA/Chandu P. Patel, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-261

Enclosures:

1. Amendment No. 210 to DPR-23

2. 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. Dan StoddardPlant General Manager H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550Mr. William G. NollDirector of Site Operations H. 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 29211J. 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. Chris L. BurtonManager Performance Evaluation and Regulatory Affairs PEB 7 Progress Energy Post Office Box 1551 Raleigh, North Carolina 27602-1551Mr. John H. O'Neill, Jr.Shaw, Pittman, Potts, & Trowbridge 2300 N Street NW.

Washington, DC 20037-1128

ML062210509. NRR-058OFFICELPL2-2/PMLPL2-2/LADE/EICBOGCLPL2-2/BCNAMECPatelCSolaAHowe (by memo dated)MZoblerJDixon-HerrityDATE 9/25/069/25/06 08/04/06 08/21/06 09/22/06 CAROLINA POWER & LIGHT COMPANYDOCKET NO. 50-261H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 210Renewed License No. DPR-231.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Carolina Power & Light Company(the licensee), dated August 20, 2004, as supplemented by letters dated June 22, 2005, June 26, 2006, and September 18, 2006, complies with thestandards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 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 theCommission's regulations;D.The issuance of this amendment will not be inimical to the common defenseand security 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 hereby amended and paragraph 3.B. of Renewed FacilityOperating License No. DPR-23 is revised to read as follows: B. Technical SpecificationsThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 210, are hereby incorporated in the license. Carolina Power &

Light Company shall operate the facility in accordance with the TechnicalSpecifications.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/ Jennifer Dixon-Herrity, Acting Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-23Date of Issuance: September 22, 2006 ATTACHMENT TO LICENSE AMENDMENT NO. 210RENEWED FACILITY OPERATING LICENSE NO. DPR-23DOCKET NO. 50-261Replace page 3 of Renewed Facility Operating License No. DPR-23 with the attac hed 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 PagesInsert Pages3.3-133.3-133.3-153.3-15 3.3-173.3-17 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 210 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 letter dated August 20, 2004, the Carolina Power & Light Company (licensee) submitted arequest for modifications to the Technical Specification (TS) Allowable Values (AVs) for four Reactor Protection System functions and one Engineered Safety Feature Actuation System function. In addition the letter requested deletion of a Technical Specification footnoteconcerning mode applicability that the licensee has deemed to be unnecessary. In response tothe Nuclear Regulatory Commission (NRC) staff requests for additional information, thelicensee submitted supplemental material by letters dated June 22, 2005, June 26, 2006, andSeptember 18, 2006.The June 22, 2005, June 26, 2006, and September 18, 2006, letters provided clarifyinginformation that did not change or expand the scope of the initial proposed no significant hazards consideration determination.The requested changes are as follows:

1. TS Table&FunctionDescriptionSystemCurrent AVProposed AVproposedTS limitis ...13.3.1-1 3Intermediate Range Neutron FluxRPS37.02%power36.40morerestrictive23.3.1-1 9RCS Flow - LowRPS93.47%flow93.45lessrestrictive33.3.1-1 14SG Water Level - Low Coincident withSteam Flow / Feedwater Flow MismatchRPS7.06E5lbm/hr7.01E5morerestrictive43.3.1-1 17aIntermediate Range Neutron Flux P6InterlockRPS7.29E-11amp9.34E-11morerestrictive #TS Table&FunctionDescriptionSystemCurrent AVProposed AVproposedTS limitis ...53.3.1-1 20Automatic Trip Logic(editorial change to applicability notes)RPSn/an/an/a63.3.2-1 1gHigh Steam Flow in 2 Steam linesCoincident with Steam Line Pressure -

LowESFAS605.05psig597.76lessrestrictiveThe licensee indicates that the requested AV changes result from a review of setpointcalculations and the associated current AVs. By the September 18, 2006, letter, the licenseewithdrew changes 2 and 6 in the table above.

2.0 REGULATORY EVALUATION

The NRC staff's evaluation of the proposed changes is based upon the following:

!10 CFR Part 50.36 "Technical specifications"

!10 CFR Part 50, Appendix A, General Design Criterion 10 "Reactor design"

!10 CFR Part 50, Appendix A, General Design Criterion 20 "Protection system functions"

!Regulatory Guide 1.105, "Setpoints for Safety-Related Instrumentation," Revision 310 CFR 50.36 Section (c)(1)(ii)(A) specifies that: "Where a limiting safety system setting isspecified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit isexceeded."10 CFR 50.36 Section (c)(3) specifies that: "Surveillance requirements are requirementsrelating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained ..."General Design Criterion (GDC) 10 requires, in part, that the reactor core and associatedcoolant, control, and protection systems must be designed with appropriate margin to assurethat specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.GDC 20 requires, in part, that protection systems be automatically initiated so as to ensure thatfuel design limits are not exceeded. It also requires that protection systems sense accidentconditions and initiate the operation of systems and components important to safety.Regulatory Guide 1.105, "Setpoints for Safety-Related Instrumentation," provides guidance oninstrument setpoint methodology. The NRC staff positions regarding the two sections of 10 CFR 50.36 cited above have beendiscussed with industry in multiple public meetings, and are reflected in letters dated March 31, August 23, and September 7, 2005, from the NRC to Nuclear Energy Institute. In summary, theNRC staff position on the cited requirements is that they:(NRC staff position 1) - Require that the setpoint be restored to some measured value("As-Left" value, or "AsL") that is within a prespecified tolerance band ("Setting Tolerance," or "ST") of a prespecified target value ("Nominal Setpoint," or "NSP") at the conclusion of periodic testing.(NRC staff position 2) - Require that the NSP be no less conservative than aprespecified limit, the "Limiting Setpoint," derived in such a manner as to include consideration of all aspects of measurement uncertainty.(NRC staff position 3) - Require that, if the measured value of the setpoint at thebeginning of a periodic test (the "As-Found" value, or "AsF") is different from the previous AsL by more than a prespecified Deviation Limit (DL), the channel be submitted for evaluation and possible repair or other corrective action. DL is the maximum amount by which the measured value of the setpoint is expected to changeover the test interval in the absence of malfunction, with 95/95 confidence. Setpoint deviation may be evaluated by comparing the As-Found Setpoint with the Nominal Setpoint, rather than with the previous As-Left Setpoint, if the Setting Tolerance is suitably constrained and, in particular, does not exceed the DL.NRC staff positions (1) and (2) ensure that a setpoint will initiate the associated action at anactual process variable value that is consistent with the intended function despite uncertainty inthe actual trippoint associated with a measured setpoint value. The NRC staff positions alsosupport conformance to GDC 10 and 20 by ensuring that the safety systems function inaccordance with the safety analyses.NRC staff position (3) ensures that appropriate action is taken if a channel is found not to beperforming in accordance with the assumptions upon which the limiting setting is based. If a channel is not performing in accordance with those assumptions, then either the assumptions are inappropriate and the analysis - and possibly the associated channel limits - must be revised, or the equipment is malfunctioning and must be repaired or replaced. In either case, the proper operation of the channel is compromised and the channel is inoperable until appropriate corrective action has been taken.For LSSS upon which no SL has been placed, the guidance from the NRC staff position 3 maybe addressed outside the TS in an appropriately-controlled and controlling document, such assurveillance test procedures. These guidances themselves are no different from those applicable to SL-related TS, but it is not necessary for those guidances be expressed in the TS.GDC 20 requires that automatic initiation of protection systems protect the fuel design limits,which in turn requires that automatic initiation be in accordance with the safety analyses which show that the fuel limits are protected. NRC staff positions 1 and 2 provide assurance thatinitiation will occur at an appropriate value despite anticipated error in the actual trip value ascompared with the measured setpoint. GDC 10 requires that key systems be designed with appropriate margin. NRC staff positions 1and 2 provide assurance that this margin is not compromised by anticipated uncertainties in instrument channel setpoints.

3.0 TECHNICAL EVALUATION

The table in Section 1 of this Safety Evaluation identifies the functions that the licenseeoriginally intended to modify. However, by letter dated September 18, 2006, the licensee withdrew the request for changes 2 and 6. These changes will not be discussed further by theNRC staff. Changes 1, 3, and 4 affect the reactor trips that are not credited in any safetyanalysis, and therefore constitute LSSS upon which no SL has been placed. Change 5 is administrative and has no technical implications. The table is repeated here, modified to explicitly indicate the foregoing:

1. TS Table&FunctionDescriptionSystemSL-Related?proposedTS limitis ...YESNO13.3.1-1 3Intermediate Range Neutron FluxRPSmorerestrictive23.3.1-1 9RCS Flow - LowRPS--withdrawn33.3.1-1 14SG Water Level - Low Coincident withSteam Flow / Feedwater Flow MismatchRPSmorerestrictive43.3.1-1 17aIntermediate Range Neutron Flux P6InterlockRPSmorerestrictive53.3.1-1 20Automatic Trip Logic(editorial change to applicability notes)RPSn/an/an/a63.3.2-1 1gHigh Steam Flow in 2 Steam LinesCoincident with Steam Line Pressure -

LowESFAS--withdrawn3.1 General Discussion of Proposed Changes to Allowable ValuesThe current TS specify an "Allowable Value" and a "Nominal Trip Setpoint" for each function. The proposed modifications (except for modification 5, which is addressed separately below) change the AVs for various functions. They do not make any other changes to the TS.Regarding NRC staff Position 1: The current TS include a note on each page that is affectedby the requested changes. This note indicates that a channel may be declared OPERABLE if the associated setpoint is reset to within its established calibration tolerance band of the Nominal Setpoint whenever it is found to be outside that band, provided it has been found to be conservative relative to the AV. This reset provision, together with the proper selection of thenominal setpoint, ensures that a safety system will initiate action at an actual process variable value that is consistent with the intended function despite uncertainty in the actual trippointassociated with a measured setpoint value. It is this reset provision, rather than provisionsrelating to the AV that ensures that the channel will perform in accordance with the SafetyAnalyses. This reset provision is consistent with the requirements of 10 CFR 50.36(c)(1)(ii)(A).

Therefore, the licensee proposed TS changes are consistent with NRC staff Position 1 andmeet the requirements of 10 CFR 50.36(c)(1)(ii)(A). Regarding NRC staff Position 2: The licensee has stated that the nominal setpoints reflected inthe TS and in the associated procedures are in accordance with the licensee's uncertainty analyses. The licensee has stated that those uncertainty analyses are in accordance with a methodology that has been submitted for NRC staff review in connection with the requested TSchanges. NRC staff has reviewed the submitted methodology, and on the basis of that review,concludes that the methodology is consistent with the provisions of Regulatory Guide 1.105 andthat setpoint values computed in accordance with that methodology would therefore beadequately conservative. This method of establishing nominal setpoints, together with the resetprovisions described in regard to NRC staff position 1, ensures that a safety system will initiateaction at an actual process variable value that is consistent with the intended function despiteuncertainty in the actual trippoint associated with a measured setpoint value. Therefore theproposed TS changes are consistent with NRC staff Position 2 and meet the requirements of10 CFR 50.36(c)(1)(ii)(A).Regarding NRC staff Position 3: The licensee has stated that the calibration proceduresrequire assessment of channel operability and initiation of corrective action if the As-Foundsetpoint is outside the As-Left limits. The licensee has also stated that, for the TS functionsaddressed in the requested changes, the AsF / AsL acceptability band does not include anyallowance for anticipated setpoint drift. This procedural requirement is considerably more restrictive than the AV-based requirement in the TS. Notably, this limitation does not takeanticipated drift into account, and so places a more restrictive limit upon the acceptable amount of setpoint deviation than might otherwise be expected. It is this procedural AsF limitation,rather than the proposed AVs, that establishes channel operability. Based on this, the NRCstaff finds that the proposed TS changes are consistent with NRC staff Position 3 and meet therequirements of 10 CFR 50.36(c)(3). 3.2 Changes not Related to a Safety Limit (# 1, 3, 4)Changes 1, 3, and 4 apply to functions which are not credited in any plant safety analysis. TheLSSS for these functions are therefore not subject to SLs. As explained above in the discussion of the requirements of 10 CFR 50.36, LSSS upon which no SL has been placed can have reset provisions and deviation assessment provisions expressed in calibration or test procedures outside the TS. Also, as explained above, the reset requirement and limit, and As-Found deviation assessment requirements, are all adequately expressed in the TS themselves or in applicable plant procedures. The proposed TS modifications for changes 1, 3, and 4 are therefore in accordance with the requirements of 10 CFR 50.36(c)(1)(ii)(A) and 10 CFR 50.36(c)(3). As shown in the first table, changes 1, 3, and 4 would make the TS more restrictive than theyare at present. The licensee has indicated that the current TS are not sufficiently conservative. The proposed TS changes therefore address a known deficiency in the existing TS.Changes 1, 3, and 4 are, therefore, acceptable.

3.3 Editorial

Change (#5)Change 5 requested removal of note "j" pertaining to the applicability of Function 20, "AutomaticTrip Logic" under Mode 1. The note limits applicability regarding the source-range neutron fluxdetector channels to power levels below the P6 interlock. The licensee indicates that this note is not necessary "because the Automatic Trip Logic function is only required to be operable when the associated reactor protection functions are required to be operable." Function 4, "Source Range Neutron Flux," is not applicable under Mode 1. Therefore this request was found to be acceptable. 4.0

SUMMARY

The changes requested for RCS Flow - Low and High Steam Flow in 2 Steam Lines Coincidentwith Steam Line Pressure - Low (changes 2 and 6) are withdrawn by licensee. The NRC staffhas concluded, based on the considerations discussed above that all other changes in theapplication are acceptable.

5.0 STATE CONSULTATION

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

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20. The NRC staff hasdetermined that the amendment involves no significant increase in the amounts, and nosignificant change in the types, of any effluents that may be released offsite, and that there isno significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (69 FR 68182). Accordingly, the amendment meets the eligibility criteria for categoricalexclusion 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 byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendment will not be inimical to thecommon defense and security or to the health and safety of the public.Principal Contributor: Paul Rebstock Date: September 22, 2006