RNP-RA/13-0002, License Amendment Request to Modify Technical Specification 3.1.7 to Delete the Monthly Rod Position Indication Surveillance Requirements
| ML13182A019 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/07/2013 |
| From: | Wheeler-Peavyhouse S A Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RNP-RA/13-0002 | |
| Download: ML13182A019 (25) | |
Text
i..Sharon A. Wheeler-Peavyhouse DUKE H. B. Robinson Steam ElectricE Plant Unit ENERGY. Manager -Support Services Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 0: 843 857 1584 F: 843 857 1319 Sharon. Wh1eler(aduke-energy.com Serial: RNP-RA/13-0002 10 CFR 50.90 JUN 0 7 2013 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 LICENSE AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION 3.1.7 TO DELETE THE MONTHLY ROD POSITION INDICATION SURVEILLANCE REQUIREMENTS
Dear Sir or Madam:
Pursuant to 10 CFR 50.90, Duke Energy Progress, Inc., formerly known as Carolina Power and Light Company, hereby requests an amendment to the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP) renewed facility operating license DPR-23, Appendix A, Technical Specifications.
The proposed license amendment will delete the current HBRSEP Surveillance Requirements 3.1.7.1, 3.1.7.2, and 3.1.7.3 of Technical Specification (TS) 3.1.7, "Rod Position Indication," and renumber current SR 3.1.7.4 as SR 3.1.7.1. This change deletes a redundant surveillance requirement and eliminates a minimum of eight reactivity manipulations per year.The Enclosure provides the basis for the proposed change, including a detailed description, technical and regulatory evaluations, environmental considerations, and Duke Energy Progress, Inc.'s determination that the proposed change does not involve a significant hazards consideration.
The proposed marked-up and retyped Technical Specifications (TS) pages are provided in Attachments 1 and 2 to the Enclosure respectively.
Marked-up TS Bases are included in Attachment 3 to the Enclosure for information.
Although impacting the same TS as the H. B. Robinson License Amendment Request submitted by letter dated June 8, 2012 (Accession Number ML12172A260), and issued by the NRC as Amendment No. 233 to the H. B. Robinson Operating License (Accession Number ML13101A369), this License Amendment Request affects only the Surveillance Requirements for TS 3.1.7, whereas, the previous submittal affected only the Limiting Condition for Operation (LCO) for TS 3.1.4 and 3.1.7. These are separate sets of TS pages which do not overlap.
United States Nuclear Regulatory Commission Serial: RNP-RA/13-0002 Page 2 of 2 Approval of the proposed amendment is requested by May 30, 2014. Once approved, the amendment shall be implemented within 120 days.This letter contains no new Regulatory Commitments.
In accordance with 10 CFR 50.91(b), a copy of this application is being provided to the State of South Carolina.
If you have any questions regarding this submittal, please contact Mr. Richard Hightower, Supervisor
-Regulatory Affairs at (843) 857-1329.I declare under penalty of perjury that the foregoing is true and correct. Executed On: .T4ne 'I 20 13 Sincerely, Sharon Wheeler-Peavyhouse Manager -Support Services -Nuclear SWP/sc Enclosure cc: Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)Mr. V. M. McCree, NRC Region II Ms. A. T. Billoch-Col6n, NRC Project Manager, NRR NRC Resident Inspectors, HBRSEP Mr. A. Wilson, Attorney General (SC)
United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0002 Page 1 of 13 ENCLOSURE Evaluation of Proposed Change to Technical Specification Rod Position Indication Surveillance Requirements 1.0
SUMMARY
DESCRIPTION
2.0 DETAILED
DESCRIPTION
3.0 TECHNICAL
EVALUTION
4.0 REGULATORY EVALUATION
4.1 Applicable
Regulatory Requirements/Criteria
4.2 Precedents
4.3 No Significant Hazards Consideration Determination
4.4 Conclusions
5.0 ENVIRONMENTAL CONSIDERATION
6.0 REFERENCES
ATTACHMENTS:
1- Proposed Technical Specifications Changes (Mark-up)2- Revised and Retyped Technical Specifications Pages 3- Proposed Changes to Technical Specifications Bases Pages United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA13-0002 Page 2 of 13 1.0
SUMMARY
DESCRIPTION Pursuant to 10 CFR 50.90, Duke Energy Progress, Inc., is hereby requesting an amendment to the H. B. Robinson Steam Electric Plant Unit No. 2 (HBRSEP) renewed facility operating license DPR-23, Appendix A, Technical Specifications (TS) 3.1.7, Rod Position Indication Surveillance Requirements.
The proposed amendment would delete the current HBRSEP Surveillance Requirements 3.1.7.1, 3.1.7.2 and 3.1.7.3 of Technical Specification (TS) 3.1.7, "Rod Position Indication," and renumbers the current SR 3.1.7.4 as SR 3.1.7.1.2.0 DETAILED DESCRIPTION Currently there are four surveillance requirements associated with TS 3.1.7. These surveillance requirements were introduced at the time of conversion from a custom TS (CTS) to a set of Technical Specifications based on NUREG-1431, "Standard Technical Specifications Westinghouse Plants," dated September 1992, including approved travelers used in the issuance of Revision 1 dated April 1995 issued as Amendment 176 (Reference 6.1).The current surveillance requirements were introduced in Supplement 4 of the original request to convert from CTS. The justification for differences stated that the additional SRs 3.1.7.1, 3.1.7.2, 3.1.7.3 and 3.1.7.4 were being provided consistent with current plant practice and licensing basis reflected in CTS Table 4.1-1 (items 9 and 10) and approved in HBRSEP Unit 2 Amendment 48.The proposed license amendment would modify Appendix A, Technical Specifications, by deleting SRs 3.1.7.1, 3.1.7.2 and 3.1.7.3 and renumbering the current SR 3.1.7.4 as SR 3.1.7.1.The deletion of current SR 3.1.7.1 eliminates a redundant requirement to compare the analog rod position indication of rods at bank positions equal to or greater than 200 steps every twelve (12)hours or once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following more than 6 inches of rod motion when the rod deviation monitor is inoperable.
In TS 3.1.4, "Rod Group Alignment Limits," SR 3.1.4.1 already requires comparison of the analog position indication of all control rods, including those at bank positions greater than or equal to 200 steps, every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> thereafter when the rod position deviation monitor is inoperable.
SRs 3.1.7.2 and 3.1.7.3 require that rod banks be moved a nominal 19 steps every 31 days and that, upon returning the rods to their original positions, the individual rod position indications be verified to be within alignment limits based on the associated bank demand position indication.
These alignment limits are the same as the rod alignment limits of SR 3.1.4.2, which also requires that rods be moved periodically, but only requires that rods be moved > 10 steps at least every 92 days. As stated in the Bases for SR 3.1.4.2 moving each control rod by 10 steps will not United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0002 Page 3 of 13 cause radial or axial power tilts, or oscillations to occur. The 92 day FREQUENCY takes into consideration other information available to the operator in the control room and SR 3.1.4.1, which is performed more frequently, adds to the determination of OPERABILITY of the rods.Deletion of SRs 3.1.7.2 and 3.1.7.3 will result in less frequent rod motion being required (every 92 days instead of 31), as well as less rod motion (10 steps instead of 19) being required during performance of the surveillance to confirm analog rod position indication system and bank demand position indication system capability to respond to rod motion. The deletion of these SRs will eliminate a monthly reactivity manipulation (reduction of reactor power to less than 98%) to meet the 19 step rod motion requirement.
Deletion of SRs 3.1.7.2 and 3.1.7.3 does not result in less frequent checks than what is required to satisfy the individual rod alignment limits of TS Limiting Condition for Operation (LCO) 3.1.4.Deletion of SRs 3.1.7.2 and 3.1.7.3 does not change the requirement that individual rod positions be verified to be within applicable alignment limits with a nominal frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as required by SR 3.1.4.1.The surveillance and frequency of SR 3.1.7.4 is renumbered as SR 3.1.7.1. Current SR 3.1.7.4 specifies that a calibration of the analog rod position indication system is to be performed with a FREQUENCY of 18 months. Discussion of SR 3.1.7.4 in the Bases identifies the Frequency of 18 months is approximately every refueling outage and that the test verifies that the channel responds to the measured parameter with the necessary range and accuracy.The renumbered SR 3.1.7.1 requires using a plant procedure, Rod Position Indication System, which provides the instruction to calibrate and align the Rod Position Indication System. This procedure is required to be done in Mode 3, Hot Standby, to calibrate the individual rod position indication system to satisfy the CHANNEL CALIBRATION requirement.
The required FREQUENCY of once every 18 months is appropriate given that the reactor needs to be in Hot Standby to perform the CHANNEL CALIBRATION of the ARPI System.The above changes are reflected in the mark-ups presented in Attachment 1 such that the single surveillance requirement for TS 3.1.7, labeled SR 3.1.7.1, is presented on page 3.1-18 and text is included on page 3.1-19 to indicate that the page was intentionally left blank. Retyped Technical Specifications pages consistent with the proposed change are presented in Attachment 2.Changes to the Bases are presented in Attachment 3 for information.
3.0 TECHNICAL
EVALUATION There are 45 full-length rod control cluster assemblies that are divided into a shutdown group comprising two shutdown banks of 8 rod clusters each and a control group, containing banks of 8, 8, 8, and 5 rod clusters.
Each control bank is divided into subgroups to obtain smaller incremental reactivity changes.
United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RAI13-0002 Page 4 of 13 Each rod control cluster assembly is connected to a grooved drive shaft which extends upward from the core into a pressure housing attached to the reactor head. Inside the pressure housing is a latch assembly.
The rod control system sends a sequence of signals to three magnetic coils located on the outside of the pressure housing which induce magnetic flux through the pressure housing to operate stationary and movable gripper latches. The sequence of signals for withdrawal of a rod cluster is the reverse of the sequence for insertion.
Each sequence of signals raises or lowers the drive shaft one groove relative to the stationary latches. The grooves on the drive shaft are spaced 5/8 inches apart over the nominal 144 inches of rod travel resulting in approximately 144*8/5 or 230 latched steps from fully inserted to fully withdrawn.
The rod control system counts the number of demand signals sent to each subgroup of rods and provides the output of electronic add-subtract counters for each subgroup for display as the number of steps of rod withdrawal.
The step counter values are known both as the group demand step counter indication and the bank demand position indication since the rod control system requires the demand step counter values of each subgroup in a bank to differ by no more than one step. The group demand step counter value is an indication of the net number of withdrawal sequence demand signals sent by the rod control system to the control rod drive mechanisms for the rods in that subgroup.A separate indication of rod position is provided by the rod position indication system. The rod position indication system uses a 144 inch tall stack of cylindrically-wound differential transformers on the outside of the rod travel housing to span the nominal length of drive shaft travel. The differential transformer output changes as the top of the ferromagnetic drive shaft moves within the rod travel housing inside the upper section of the pressure housing. The rod position indication system provides an analog indication of the actual individual rod position in units of inches withdrawn and is also referred to as the analog rod position indication (ARPI)system.The rod control system also includes a deviation monitor which compares the outputs of the bank (group) demand (step counter) position and analog rod position and actuates an alarm when the two position indications differ by more than a preselected value.The movement of rods for the purpose of demonstrating the capability of the rods to move has been periodically performed since initial plant startup. Until 1983, Periodic Test (PT)-21.2 was performed every two weeks by moving rods a nominal 19 steps with completion of the test used to satisfy the requirements of Item 2 of Table 4.1-3 and Item 9 of Table 4.1-1 of the then current CTS. In 1983, PT- 21.2 Revision 4 was revised and renamed Operations Surveillance Test (OST)-01 1.Until the conversion to the Improved Standard Technical Specification (ISTS) format, Item 2 of CTS Table 4.1-3 specified that a check involving partial movement of all full length control rods United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RAI13-0002 Page 5 of 13 was required at a frequency of two weeks with a maximum time between tests of 20 days.During this same period, Item 9 of CTS Table 4.1-1 specified a check of the analog rod position (indication) every shift, a test every month, and a calibration each refueling outage. The results of OST-01 1 were used to meet the monthly testing of the rod position indication required by Item 9 of CTS Table 4.1-1 and the every two weeks requirement for partial movement of control rods required by Item 2 of CTS Table 4.1-3 during this period.In 1997, the CTS were converted to a set of TS based on NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Revision 0, dated September 1992, including approved travelers used in the issuance of Revision 1, dated April 1995. In the ISTS format, partial movement of control rods is required by SR 3.1.4.2. Surveillance of the functionality of the rod position indication systems are implicit in the requirement that individual rod positions be verified to be within alignment limits (SR 3.1.4.1).
In addition, it is also required that the two rod position indication systems, the analog rod position indication and bank (group) demand (step counter)position indication systems agree within 12 steps. The requirements of ISTS 3.1.7 do not include surveillance requirements separate from the requirements of SR 3.1.4.2 for the purpose of demonstrating the functionality of the rod position indication systems.The proposed change is intended to eliminate redundant surveillance requirements (SR 3.1.7.1), and, reduce the potential for, and the frequency of, reactivity manipulations that result in power level changes by eliminating monthly partial rod movements of 19 steps (SRs 3.1.7.2 and 3.1.7.3)to demonstrate the functionality of the rod position indication system.Current HBRSEP TS SR 3.1.4.1 requires verification that individual rod positions are within the alignment limits every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> thereafter when the rod position deviation monitor is inoperable.
In comparison, current HBRSEP TS SR 3.1.7.1 requires a channel check of those rods at bank positions equal to or greater than 200 steps with a frequency of once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following greater than 6 inches of rod motion when the rod position deviation monitor is inoperable.
The required channel check of SR 3.1.7.1 is specified to be a comparison of the (individual) analog rod position indications and the bank (group) demand (step counter) position indication.
The TS Bases discussion for SR 3.1.7.1 indicates the criterion for a successful channel check is based on meeting the requirement of TS LCO 3.1.4, "Rod Group Alignment," Item a. SR 3.1.4.1 meets the requirements of TS 3.1.4 for all rods regardless of bank (group) demand (step counter) position and at a frequency which is the same as the requirement for the frequency of performing SR 3.1.7.1 with the rod deviation monitor operable (every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />).SR 3.1.4.1 also meets the requirements of TS 3.1.4 at a frequency that is the same or more frequent when the rod deviation monitor is inoperable since once within four hours and every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> thereafter is at least as frequent as once within four hours following rod motion of greater than six inches.
United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RAI13-0002 Page 6 of 13 Based on the above discussion, it is concluded that the requirements of current HBRSEP TS SR 3.1.7.1 is a subset of the requirements of SR 3.1.4.1 and therefore SR 3.1.7.1 is redundant and can be deleted.At the time of the conversion to the Technical Specifications format based on NUREG-1 431,"Standard Technical Specifications Westinghouse Plants," HBRSEP TS SR 3.1.7.2 and SR 3.1.7.3 were introduced with no explicit discussion or justification for the specification that full length control rods be moved a nominal 19 steps.An implicit justification for the specification of control rod movement by a nominal 19 steps was presented in Item 14 of the Justification for Differences for ITS Section 3.1 -Reactivity Control Systems. Item 14 included the following statement:
These SRs (SRs 3.1.7.1 through 3.1.7.4) are provided consistent with current plant practice and licensing basis reflected in CTS Table 4.1-1 (Items 9 and 10) and approved in Amendment No. 48.Amendment 48 implemented changes to CTS 3.10.1.5 (page 3.10-2) to specify bank demand position dependent alignment limits. These alignment limits were retained by incorporating them into LCO 3.1.4 when the CTS were converted to the new format. These alignment limits were also explicitly repeated in the requirements of SRs 3.1.7.2 and 3.1.7.3. As neither Items 9 nor 10 of CTS Table 4.1-1 nor Amendment 48 specify movement of full length control rods a nominal 19 steps, it is concluded that inclusion of 19 steps in SRs 3.1.7.2 and 3.1.7.3 was based on plant practice, i.e., PT 21.2/OST-011.
As noted previously, PT 21.2/OST-01 1 was used to meet the requirements of Item 2 of CTS Table 4.1-3 as well as Items 9 and 10 of CTS Table 4.1-1. The mark-up of the then current CTS Table 4.1-3 in the ISTS conversion submittal indicates that the requirement for partial movement of control rods specified in Item 2 is matched to ISTS LCO 3.1.4. Based on Item 2 of CTS Table 4.1-3 being converted to ISTS LCO 3.1.4, a more appropriate and consistent conversion of the plant practice to move rods 19 steps in accordance with PT 21.2/OST-01 1, would have been to modify ISTS SR 3.1.4.2 to 19 steps with a frequency of two weeks. Instead, the plant practice of moving rods 19 steps was reflected in SRs 3.1.7.2 and 3.1.7.3 with a frequency of 31 days.Specification of a frequency of 31 days for SRs 3.1.7.2 and 3.1.7.3 is, however, consistent with the monthly testing frequency listed for the analog rod position indication system (Item 9) of CTS Table 4.1-1.In contrast to current SRs 3.1.7.2 and 3.1.7.3, the ISTS do not contain surveillance requirements testing the bank position indication systems by control rod movement.
Rather, the functionality of the bank position indication systems is implicitly checked each time the bank demand position is compared with the rod position indication to satisfy SR 3.1.4.1 with a frequency of every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as discussed in the bases for ISTS SR 3.1.4.1. The functionality of the bank position systems is further exercised during performance of SR 3.1.4.2 when control rods are moved greater than or United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0002 Page 7 of 13 equal to (>) 10 steps to verify freedom of movement (trippability) of control rods.As discussed in the TS Bases for SR 3.1.4.2, the objective of periodic rod exercising is to increase the confidence that all rods continue to be operable without exceeding the alignment limit even if they are not regularly tripped. Periodic rod exercising, involving movement of each control rod not fully inserted, by > 10 steps, does not cause radial or axial power tilts, or oscillations that might result from tripping control rods in Modes 1 or 2. In contrast, moving each full length RCCA bank>19 steps and returning the banks to their original positions as required by OST-01 1 is considered a reactivity management event and requires a reduction in reactor power to less than 98% of full power to perform this surveillance test.Upon elimination of SRs 3.1.7.2 and 3.1.7.3, the requirements of SR 3.1.4.2 will remain and require less frequent (92 days versus 31 days) and smaller changes in reactivity due to rod movement (10 steps versus 19 steps). The combination of less frequent reactivity evolutions and smaller changes in reactivity reduce the potential challenges to operation while performing surveillance consistent with the requirements of industry standards of SR 3.1.4.2.The proposed change also renumbers the SR 3.1.7.4 to make it SR 3.1.7.1. The renumbered surveillance requirement is due to the elimination of SRs 3.1.7.1, 3.1.7.2, and 3.1.7.3.Current SR 3.1.7.4 requires calibration of the individual analog rod position indications once every 18 months or approximately once per refueling outage. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy.
The 18 month Frequency is based on the need to perform this Surveillance under conditions that apply during Hot Standby conditions and eliminates the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
4.0 REGULATORY EVALUATION
4.1 ADolicable
Reaulatorv Reauirements/Criteria The General Design Criteria (GDC) applicable to HBRSEP at the time the operating license was issued (July, 1970) were those contained in Proposed Appendix A to 10 CFR 50, General Design Criteria for Nuclear Power Plants, published in the Federal Register on July 11, 1967. These criteria are described in HBRSEP UFSAR Sections 3.1.1.1 and 3.1.2. The Appendix A GDC, effective in 1971 with subsequent amendments, are somewhat different from the proposed 1967 criteria.
HBRSEP was evaluated with respect to the proposed 1967 GDC and the original FSAR contained a discussion of the criteria as well as a summary of the criteria by groups.The proposed change modifies surveillance requirements for the bank (group) demand (step counter) position indication and analog rod position indication systems. The proposed change United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RAI13-0002 Page 8 of 13 does not alter the manner or means of control by the control system of control rod drive mechanisms or any function of the protection system. The proposed change does not alter the instrumentation used to monitor control rod position and/or movement.The regulatory requirements applicable to instrumentation used to monitor the status of control system components (control rods) i.e., the analog rod position indication system and the bank (group) demand (step counter) position indication system, are the following:
1967 GDC-7 Suppression of Power Oscillations
-The design of the reactor core with its related controls and protection systems shall ensure that power oscillations, the magnitude of which could cause damage in excess of acceptable fuel damage limits, are not possible or can be readily suppressed.
1967 GDC-12 Instrumentation and Control Systems -Instrumentation and controls shall be provided as required to monitor and maintain within prescribed operating ranges for the essential reactor facility operating variables.
1967 GDC-13 Fission Process Monitors and Controls -Means shall be provided for monitoring or otherwise measuring and maintaining control over the fission process throughout core life under all conditions that can reasonably be anticipated to cause variations in reactivity of the core.1967 GDC-22 Separation of Protection and Control Instrumentation
-The physical arrangement of the redundant elements of the protection system are such that the probability is reduced that a single physical event will impair the vital function of the system.1967 GDC-27 Redundancy of Reactivity Control- Two independent control systems, preferably of different principles, shall be provided.1967 GDC-31 Reactivity Control Systems Malfunction
-The reactor protection systems shall be capable of protecting against any single malfunction of the reactivity control system, such as unplanned continuous withdrawal (not ejection or dropout) of a control rod, by limiting reactivity transients to avoid exceeding acceptable fuel damage limits.1967 GDC-32 Maximum Reactivity Worth of Control Rods -Limits, which include reasonable margin, shall be placed on the maximum reactivity worth of control rods or elements and on rates at which reactivity can be increased to ensure that the potential effects of a sudden or large change of reactivity cannot: a) Rupture the RCPB, and b) Disrupt the core, its support structures, or other vessel internals sufficiently to lose capability of cooling the core.The functions of the protection and control systems credited in the accident analyses are not changed by the proposed change. The proposed change does not diminish the capability of instrumentation and controls to monitor and maintain operating variables within prescribed United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/1 3-0002 Page 9 of 13 operating ranges or to function with high functional reliability and in-service testability.
The proposed change also does not impact the capability of any protection system to provide a protection function credited in the accident analyses subsequent to a single failure or removal from service of any system component or channel. Furthermore, the proposed change does not increase the probability that a single physical event will impair any vital function of the protection system.4.2 Precedents A precedent for the deletion of a redundant surveillance requirement, associated with the Rod Position Indication TS such as current SR 3.1.7.1, was provide by the submittal and approval of the Beaver Valley Power Station license amendment requesting conversion to an Improved Standard Technical Specification format (References 6.2 and 6.3). Specifically, on page 406 of 670 of Reference 6.2, the requirement to perform "a CHANNEL CHECK by intercomparison between each analog rod position indicator and its corresponding group demand counter at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />" is deleted with the notation of L9. On pages 481-482 of Reference 6.2, a discussion of the change L9, characterized as a less restrictive change, is presented.
In that discussion, the following statements are made: This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions.
The CTS surveillance proposed for deletion is redundant to the rod alignment limits surveillance which requires that the alignment limits (RPIs within +/- 12 steps of demand position) be verified every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.This precedent is comparable to the requested deletion of SR 3.1.7.1 which states "perform CHANNEL CHECK by comparing analog rod position indication and bank demand position indication." No precedents have been identified involving the creation or deletion of surveillance requirements associated with the rod position indication system, such as SR 3.1.7.2 and SR 3.1.7.3, which also require control rod movement.A precedent for the current TS 3.1.7.4, which will be renumbered as TS SR 3.1.7.1, is the NRC approval of the North Anna Power Station (NAPS) Conversion to Improved Technical Specifications dated April 5, 2002 (ML021200265).
In the issuance of amendments by the NRC, it was stated in Attachment 4, Table L -Less Restrictive Changes, ITS Section 3.1 -Reactivity Control Systems, on page 9 of 10, for DOC No. 3.1.7 L.4 that "CTS 4.1.3.2 requires each rod position indicator to be determined OPERABLE by performing a CHANNEL CHECK every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and a CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION at least once per 18 months. ITS SR 3.1.7.1 requires a CHANNEL CALIBRATION every 18 months. This changes the CTS by eliminating the CHANNEL CHECK and CHANNEL FUNCTIONAL TEST requirements."
United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RAI13-0002 Page 10 of 13 4.3 No Significant Hazards Consideration Determination This license amendment request proposes to delete current SRs 3.1.7.1, 3.1.7.2 and 3.1.7.3 and modify and renumber current SR 3.1.7.4 as SR 3.1.7.1. Current SR 3.1.7.1 is redundant to SR 3.1.4.1. The ISTS do not include a requirement separate from SR 3.1.4.1 for comparison of rod position indications to rod alignment criteria.Elimination of SRs 3.1.7.2 and 3.1.7.3 reduces the frequency and magnitude of control rod movement required by Technical Specifications to those specified in SR 3.1.4.2: the frequency is reduced from 31 days to 92 days and the magnitude of rod movement is reduced from 19 steps to 10 steps. Current SR 3.1.4.2 is consistent with ISTS SR 3.1.4.2 and therefore elimination of SRs 3.1.7.2 and 3.1.7.3 will result in TS which more closely follow the industry standards of the ISTS.The proposed change also modifies current SR 3.1.7.4 to renumber it SR 3.1.7.1 which requires the performance of a Channel Calibration of the ARPI System on an 18 month frequency.
Duke Energy Progress, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response:
No The initiating conditions and assumptions for dose consequences of accidents described in the Updated Final Safety Analyses Report remain as previously analyzed.
The proposed change does not introduce a new accident initiator nor does it introduce changes to any existing accident initiators described in the Updated Final Safety Analyses Report. The proposed change eliminates requirements to periodically demonstrate agreement of individual rod position with average rod position and group demand step counter position during control rod movement while maintaining less frequent requirements for control rod movement associated with verification of control rod freedom of movement (SR 3.1.4.2)and confirmation that the two rod position indication systems are within alignment limits (SR 3.1.4.1).
Control rod movement is a potential accident initiator and less frequent surveillances involving less control rod movement will not increase the probability or consequences of an accident.The proposed change also eliminates surveillance requirements which are redundant to the requirements of SR 3.1.4.1 and modifies SR 3.1.7.4 to renumber it as SR 3.1.7.1. The elimination of redundant surveillance requirements does not involve a significant increase in the probability or consequences of an accident previously evaluated.
United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0002 Page 11 of 13 Current SR 3.1.7.4 and proposed SR 3.1.7.1 involve the maintenance and configuration of instrumentation used to indicate rod position.
The proposed change renumbers SR 3.1.7.4 as SR 3.1.7.1 and maintains the requirement to perform a Channel Calibration on an 18 Month Frequency which does not change the means and manner of control of control rod movement and therefore does not involve a significant increase in the probability of consequences of an accident previously evaluated.
Based on the above, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response:
No The proposed change will not introduce any new failure modes to the required protection functions.
The proposed change modifies surveillance requirements associated with operation and function of instrumentation indicating rod position that is part of the control rod control system (demand step counter position) and individual analog rod position indication instrumentation.
The proposed change does not alter the manner in which the respective rod position indications function or the control system controls control rod movement such that the modified surveillance requirements of TS 3.1.7 cannot create the possibility of a new or different kind of accident from any accident previously evaluated.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the change involve a significant reduction in a margin of safety?Response:
No The proposed amendment does not involve revisions to any safety analysis limits or safety system settings that will adversely impact plant safety. The proposed amendment does not alter the functional capabilities assumed in a safety analysis for any system, structure, or component important to the mitigation and control of design bases accident conditions within the facility.
Nor does this amendment revise any parameters or operating restrictions that are assumptions of a design basis accident.
In addition, the proposed amendment does not affect the ability of safety systems to ensure that the facility can be placed and maintained in a shutdown condition for extended periods of time.The Technical Specifications continue to assure that the applicable operating parameters and systems are maintained within the design requirements and safety analysis assumptions.
Therefore, the proposed changes which eliminate surveillance requirements United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0002 Page 12 of 13 that are either redundant or inconsistent with industry standards for the partial movement of control rods and rod position indication system surveillance and add a new requirement that the rod position indication systems agree within a prescribed value will not result in a significant reduction in the margin of safety as defined in the Updated Final Safety Analyses Report or Technical Specifications.
Therefore, the proposed change does not involve a significant reduction in any margin of safety.4.4 Conclusions Based on the considerations above; 1) there is 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.5.0 ENVIRONMENTAL CONSIDERATION Duke Energy Progress, Inc. has evaluated the proposed amendment for environmental considerations.
The review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and would change an inspection or surveillance requirement.
However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c) (9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.
United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/13-0002 Page 13 of 13
6.0 REFERENCES
6.1 NRC Letter to Carolina Power & Light Company, "Issuance of Amendment No. 176 to Facility Operating License No. DPR-23 Regarding Conversion to Improved Standard Technical Specifications
-H. B. Robinson Steam Electric Plant Unit Number 2 (TAC NO.M96440), dated October 24, 1997 (Agencywide Documents Accession and Management System (ADAMS) Accession Number ML020560172)
6.2 Letter
to NRC from FirstEnergy Nuclear Operating Company, "Beaver Valley, Units 1 and 2 -Improved Technical Specification Conversion License Amendment Request (LAR) Nos. 296 (Unit 1) and 169 (Unit 2) Volume 1 -Review Information", dated February 25, 2005 (ADAMS Accession Number ML0506110340) 6.3 NRC Letter to FirstEnergy Nuclear Operating Company, "Beaver Valley Power Station, Unit Nos. 1 and 2 -Issuance of Amendment Re: The Conversion to the Improved Technical Specifications with Beyond Scope Issues, (TAC Nos. MC6285, MC6286, MC6579 -MC6612, MC6614 -MC6626, and MC6783 -MC6792) dated February 21, 2007 (ADAMS Accession Number ML070160593) 6.4 NRC Letter to Virginia Electric and Power, "North Anna Power Station, Units 1 and 2 -Issuance of Amendments Re: Conversion to Improved Technical Specifications (TAC Nos.MB0799 and MB0800) dated April 5, 2002 (ADAMS Accession Number ML021200265)
Enclosure to Serial: RNP-RA/13-0002 Attachment 1 3 Pages (including cover page)ATTACHMENT 1 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UP)
Rod Position Indication
3.1.7 SURVEILLANCE
REQUIR TS SURVEILLANCE FREQUENCY SR 3.1.7.1 ---------------------
NOTE----------------
Only required to be met for bank positions 200 steps.Perform CHANNEL CHECK by comparing analog 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> rod position indication and bank demand position indication.
AND Once within 4 Hours following> 6 inches of rod motion when rod position deviation monitor is inoperable SR 3.1.7.2 -----------------
NOTE --------------
Only required to be met for bank positions<200 steps.Verify each ARPI is within 7.5 inches of 31 days the average of the individual ARPIs in the associated bank after moving each full length RCCA bank 19 steps and returning the banks to their original positions.
SR 3.1.7.3 ----------------
NOTE--------------
Only required to be met for bank positions 200 steps.Verify each ARPI is within 15 inches of the 31 days associated bank demand position after moving each full length RCCA bank 19 steps and returning the banks to their original positions.
HBRSEP Unit No. 2 3.1-18 AedetN.1 Page is intentionally blank Rod Position Indication
3.1.7 SURVEILLANCE
REQUIREMENTS (continued:
SURVEILLANCE SR 3.1.7 18 months HBRSEP Unit No. 2 3 .1-19 Amendment No. 1-7-6 Enclosure to Serial: RNP-RA/1 3-0002 Attachment 2 3 Pages (including cover page)ATTACHMENT 2 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 REVISED AND RETYPED TECHNICAL SPECIFICATIONS PAGES Rod Position Indication
3.1.7 SURVEILLANCE
REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Perform CHANNEL CALIBRATION of the ARPI 18 Months System.HBRSEP Unit No. 2 3.1-18 Amendment No.
Rod Position Indication 3.1.7 PAGE IS INTENTIONALLY BLANK HBRSEP Unit No. 2 3.1-19 Amendment No.
Enclosure to Serial: RNP-RA/13-0002 Attachment 3 4 Pages (including cover page)ATTACHMENT 3 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS BASES PAGES Rod Position Indication B 3.1.7 BASES ACTIONS (continued) until power has been reduced to < 50%, at which time the Required Action C.2 would be met.With one demand position indicator per bank inoperable, the rod positions can be determined by the ARPI System. Since normal power operation does not require excessive movement of rods, verification by administrative means that the rod position indicators are OPERABLE, that the position of each rod in the affected bank(s) is within 7.5 inches of the average of the individual rod positions in the affected bank(s), for bank positions
< 200 steps and that the position of each rod in the affected bank(s) is within 15 inches of the bank demand position for bank positions
> 200 steps within the allowed Completion Time of once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is adequate.C.2 Reduction of THERMAL POWER to :<50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factors. The allowed Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provides an acceptable period of time to verify the rod positions per Required Actions C.1.1 and C.1.2 or reduce power to < 50% RTP.D.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Time is reasonable based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.SURVEILLANCE REQUIREMENTS SR 3.1.7.1~ Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following rod motion > 6 inches when the rod position deviation monitor is inoperable" ensures that a gross instrumentation failure has not occurred.
The CHANNEL CHECK of rod position indication is a comparison of the rod position indicated on analog----N--- A.__A. ) ~~~'JI I ~~II ILA~J/S)-~~C~ % )N C~ ) )~ N N HBRSEP Unit No. 2 B 3.1-47 Revision No. 36 HBRSEP Unit No. 2 B 3.1-47 Revision No. 36 Rod Position Indication B 3.1.7/BASES SURVEILLAI REQUIREMEF NCE 3.1.7.1 ronhitijed--y y> < --N T S " " v -. _ .rod position indication channels and bank demand position indication channels.
It is based on the assumption that>instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the analog rod position indication of excessive instrument drift in one of the indication channels or of something even more serious.A CHANNEL CHECK will detect gross channel failure; thus, it is the key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
The channel deviation criterion is based on meeting the requirement of LCO 3.1.4, "Rod Group Alignment Limits," item a. If a channel is outside the criteria, it may be an indication that rod position indication has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.The Frequencies of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and "once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following rod motion > 6 inches when the rod position deviation monitor is inoperable" are based on operating experience.
The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.SR 3.1.7.1 is modified by a Note which states the surveillance is only required to be met for bank positions
> 200 steps since LCO K- 3.1.4, item a, limits related to comparison of analog rod position and bank demand position inidication only apply for bank K positions
>!200 steps.( SR 3.1.7.2-Verification that each ARPI is within 7.5 inches of the average of the individual ARPIs in the associated bank after moving each full length RCCAs bank > 19 steps and then returning the banks to their original positions provides adequate assurance that each ARPI is operating correctly.
The 31 day Frequency is based on operating experience.
SR 3.1.7.2 is modified by a Note which states the surveillance is only required to be met for bank positions
< 200 steps since LCO 3.1.4, item b, limits related to comparison of analog rod position yfand the average of the individual analog rod position indications ofonly apply for bank positions
< 200 steps.1(oN 2y I)~2 B 3.1-48 HBRSEP Unit No. 2 Revision No. 36 Rod Position Indication B 3.1.7 BASES SURVEILLANCE SR 3.1.7.3 -REQUIREMENTS (continued)
Verification that each ARPI is within 15 inches of the associated bank demand position after moving each full length RCCAs bank > 19 steps and then returning the banks to their original positions provides adequate assurance that each ARPI and bank demand position indication is operating correctly.
The 31 day Frequency is based on operating experience.
SR 3.1.7.3 is modified by a Note which states the surveillance is only required to be met for bank positions>- 200 steps since LCO 3.1.4, item a, limits related to comparison of analog rod position and bank demand position indication only apply for bank positions
> 200 steps.--3SR .3 1 r7 a 4C A CHANNEL CALIBRATION of the ARPI System is performed every 18 months, or approximately at every refueling.
CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy.
The 18 month Frequency is based on the need to perform this Surveillance under conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.REFERENCES