ML14183A788
| ML14183A788 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/09/1997 |
| From: | Mozafari B NRC (Affiliation Not Assigned) |
| To: | Hinnant C CAROLINA POWER & LIGHT CO. |
| References | |
| TAC-M96440, NUDOCS 9704110175 | |
| Download: ML14183A788 (13) | |
Text
April 9, 1997 Mr. C. S. Hinnant, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATION CHANGE REQUEST TO CONVERT TO THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR THE H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 (TAC NO. M96440)
Dear Mr. Hinnant:
By letter dated August 27, 1996, you submitted a request to convert the current Technical Specifications (TS) for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR), to be consistent with the Improved Standard Technical Specifications (ISTS) in NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Revision 1, dated April 1995. To complete our review, we need additional information as indicated in the enclosed tables related to sections 1.0, 2.0, and 4.0 under the heading "Comments."
On February 24, 1997, tables with comments related to sections 3.4, 3.6, and 3.7 were sent to you. A request for additional information (RAI) was sent to you on March 28, 1997, associated with sections 3.3, 3.8, and 5.0.
To support the NRC staff's review schedule, your written response to this RAI is expected within 30 days of the receipt of this letter. Should you have any questions, do not hesitate to contact me at (301) 415-2020.
Sincerely, (Original Signed By)
Brenda Mozafari, Project Manager Project Directorate II-1 9704110175 970409 Division of Reactor Projects -
I/II PDR ADOCK 05000261 Office of Nuclear Reactor Regulation P
PDR Docket No. 50-261
Enclosure:
As stated cc w/,enclosure:
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DATE 4//97 4/ ?/97 4/
/97 COPY Yes/No fes)No Yes/No OFFICIAE-RECORD COPY
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Mr. C. S. Hinnant H. B. Robinson Steam Electric Carolina Power & Light Company Plant, Unit No. 2 cc:
Mr. William D. Johnson Mr. Mel Fry, Acting Director Vice President and Senior Counsel N.C. Department of Environment, Carolina Power & Light Company Health and Natural Resources Post Office Box 1551 Division of Radiation Protection Raleigh, North Carolina 27602 3825 Barrett Dr.
Raleigh, North Carolina 27609-7721 Ms. Karen E. Long Assistant Attorney General Mr. Robert P. Gruber State of North Carolina Executive Director Post Office Box 629 Public Staff -
NCUC Raleigh, North Carolina 27602 Post Office Box 29520 Raleigh, North Carolina 27626-0520 U.S. Nuclear Regulatory Commission Resident Inspector's Office Mr. Max Batavia, Chief H. B. Robinson Steam Electric Plant South Carolina Department of Health 2112 Old Camden Road Bureau of Radiological Health Hartsville,.South Carolina 29550 and Environmental Control 2600 Bull Street Regional Administrator, Region II Columbia, South Carolina 29201 U.S. Nuclear Regulatory Commission 101 Marietta St., N.W., Ste. 2900 Mr. T. D. Walt Atlanta, Georgia 30323 Director Operations & Environmental Mr. Dale E. Young Support Department Plant General Manager Carolina Power & Light Company Carolina Power & Light Company 412 S. Wilmington Street H. B. Robinson Steam Electric Plant Raleigh, North Carolina 27601 Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. Milton Shymlock U. S. Nuclear Regulatory Commission Public Service Commission 101 Marietta Street, N.W. Suite 2900 State of South Carolina Atlanta, Ga. 3023-0199 Post Office Drawer 11649 Columbia, South Carolina 29211 Mr. T. M. Wilkerson Manager -
Regulatory Affairs Mr. H. K. Chernoff Carolina Power & Light Company Supervisor, Licensing/Regulatory Programs H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 H. B. Robinson Steam Electric Plant, 3581 West Entrance Road Unit No. 2 Hartsville, South Carolina 29550-0790 3581 West Entrance Road Hartsville, South Carolina 29550
ITS 1.0 USE AND APPLICATION Table 1.0 Rv.1 DOC CTS/STS Description of Issue Date Date COMMENTS ITEM #
or LCO Opened Closed JFD 1-1 AS CTS 1.2.5 CTS 1.2.5 defines Power Operating Condi-11/19/96 Provide discus tion as, "When the reactor is critical sion and justifi and the neutron instrumentation indicates cation for the greater than 2% rated power," while ITS less restrictive Section 1.0 defines MODE 1 as, "... Keff change.
0.99 and % RATED THERMAL POWER > 5% (ex cluding decay heat)."
This is a less restrictive change, rather than an administrative change, because the operator is allowed an additional 3%
Rated Thermal Power before being required to meet all ITS requirements associated with MODE 1 operation. This ITS allowance also gives operators additional flexibility to scheduling and returning equipment to operable status prior to increasing thermal power to 5% that may not be permitted within the limits of current TS.
ENCLOSURE ITS 1.0 USE AND APPLICATION Table 1.0 Rv.1 0C CTS/STS Description of Issue Date Date COMMENTS ITEM #
or LCO Opened Closed JFD 1-2 A7 CTS 1.2.6 CTS 1.2.6 defines Refueling Operation as, 11/19/96 Provide discus "Any operation involving movement of core sion and justif components when there is fuel in the cation for the containment vessel...
less restrictive ITS 1.1 defines CORE ALTERATION as, "...
the movement of any fuel, sources, or reactivity control components, within the reactor vessel with...
fuel in the ves sel."
This is a less restrictive change rather than an administrative change because, by specifying which components to be moved affects whether or not CORE ALTERATIONS are ongoing, the operator has greater latitude to invoke requirements associated with CORE ALTERATIONS in the ITS. No justification is provided for this less restrictive change.
ITS 1.0 USE AND APPLICATION Table 1.0 Rv DOC CTS/STS Description of Issue Date Date COMMENTS ITEM #
or LCO Opened Closed JFD 1-3 A7 CTS 1.2.6 CTS 1.2.6 defines Refueling Operation as, 12/30/96 Provide discus "Any operation involving movement of core sion and justifi components when...
the reactor vessel cation for the head is unbolted or removed."
more restrictive ITS 1.1 incorporates the STS definition for MODE 6 - Refueling, including foot note (c) in Table 1.1-1, "One or more reactor vessel head closure bolts less than fully tensioned."
Because MODE 6 is entered, by definition, whenever the first reactor head closure bolt is de-tensioned, this change to conform to the STS results in more re strictive requirements, rather than an administrative change. There is no discussion or justification provided for this more restrictive change.
1-4 AlO CTS 1.6.2 CTS 1.6.2 defines Channel Calibration to 2/21/97 Provide discus encompass the entire channel, and does sion and justifi not exclude RTDs and thermocouples. For cation for the channels with RTDs and/or thermocouples, less restrictive the ITS definition of CHANNEL CALIBRATION change.
allows performing "...an inplace qualita tive assessment of sensor behavior..."
for these devices.
Although the change is acceptable, it represents a less restrictive change, rather than an administrative change.
ITS 1.0 USE AND APPLICATION Table 1.0 Rv.1 DOC CTS/STS Descri pti on of Issue Date Date COMMENTS ITEM #
or LCO Opened Closed J FD 1-5 All CTS 1.10 CTS 1.10 defines Staggered Test Basis as 2/21/97 Provide discus testing n systems, subsystems, etc. with-sion and justifi in the interval specified by the Surveil-cation for the lance Frequency, where n is the total less restrictive number of systems, subsystems, etc.
change.
ITS 1.1 defines STAGGERED TEST BASIS as testing n systems, subsystems, etc.,
within n Surveillance Frequency Inter vals.
The justification provided states this change is administrative, because the impact of this change is individually evaluated for each applicable surveil lance. It is appropriate to address the impact of this change for each applicable surveillance. However, doing that does not cause this change to be administrative. This change relaxes technical requirements, and is therefore a less restrictive change.
ITS 1.0 USE AND APPLICATION Table 1.0 Rv.1 00C CTS/STS Description of Issue Date Date COMMENTS ITEM #
or LCO Opened Closed JFD 1-6 A13 CTS 1.6.4 The CTS 1.6.4 definition for Channel 2/24/97 Provide discus Functional Test does not specify the sion and justif point of test signal injection.
cation for the more restrictive The ITS 1.1 definition for CHANNEL OPERA-change.
TIONAL TEST (COT) requires, "
injection of a signal into the channel as close to the sensor as practicable The justification provided states, "...
inclusion of the sensor in the test is implied when such inclusion is practical.
When including the sensor is practical, it is generally the point of signal in jection."
This change is a more restrictive change rather than an administrative change, because technical requirements are added with regard.to where in the circuitry the test signal is inserted.
ITS 1.0 USE AND APPLICATION Table 1.0 Rv.1 DOC CTS/STS Description of Issue Date Date COMMENTS ITEM #
or LCO Opened Closed JFD 1-7 None STS 1.1 STS 1.1 definition for DOSE EQUIVALENT 2/24/97 Provide justifi 1-131 stipulates the thyroid dose conver-cation for the sion factors shall be those listed in STS deviation Table E-7 of Regulatory Guide 1.109, Rev.
based on current 1, NRC, 1977. The ITS 1.1 definition licensing basis, does not include the Table E-7 require-system design, or ment, stating only that the thyroid dose operational con conversion factors shall be those listed straints.
in Regulatory Guide 1.109, Rev. 1, NRC, 1977. Table E-7, Inhalation Dose Factors for Adults, is one of four tables of inhalation dose factors, the other three being for teenagers, for children, and for infants.
There is no discussion or justification for this deviation from the STS.
HBR ITS 2.0 SAFETY LIMITS Table 2.0 Rv.1 ITEM #
DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed 3 FD 2-1 Al CTS CTS Figure 2.1-1 is limited, on the 11/21/96 Provide discus Figure right, by a "High Flux Trip at 115% of sion and justifi 2.1-1 Rated Power" dashed line.
cation for this less restrictive ITS Figure 2.1.1-1 allows operation to change.
120% of Rated Thermal Power.
This represents a less restrictive change for which there is no discussion or jus tification.
2-2 L1 CTS 2.2 CTS 2.2 requires that RCS pressure shall 11/22/96 Provide adequate not exceed 2735 psig with fuel assemblies justification for installed in the reactor, and makes no this Less Re qualifying statement about reactor vessel strictive change.
head closure bolts being less than fully tensioned while fuel assemblies are in stalled in the reactor.
ITS 2.1.2 requires that RCS pressure will be maintained < 2735 in MODES 1, 2, 3, 4, and 5.
There is inadequate justification for this change, as it applies to one or more reactor vessel head closure bolts less than fully tensioned (ITS MODE 6), while fuel assemblies are installed in the reactor.
HBR ITS 2.0 SAFETY LIMITS Table 2.0 Rv.1 ITEM #
DOC CTS/,SIS Description of Issue Date Date COMMENTS or LCO opened Closed JFD 2-3 LAI CTS CTS 6.7.1.c, 6.7.1.d, and 6.7.1.e 11/25/96 Provide adequate 6.7.1.c, requirements are removed from the ITS.
justification for 6.7.1.d, The justification provided states that the Less Restric and they are "... not required in the ITS to tive change.
6.7.1.e provide adequate protection of the public health and safety, since the ITS retains the requirement for compliance with the safety limits."
There is inadequate justification for this less restrictive change.
2-4 JFD1 Change to CTS parameters for Reactor Core 4/1/97 Provide Safety Limits. STS use "RCS highest loop additional average temperature," ITS proposes "RCS information.
highest cold leg temperature," and the CTS does not specify where the loop temperature is measured.
The JFD states that the proposed values are conservative since the proposed "highest" values bound the other loop conditions with respect to impact on the fuel safety limits. Provide additional information to prove that the proposed limits establish bounding conditions.
Explain the safety significance of these changes as they affect CTS safety.limits.
HBR ITS 4.0 DESIGN FEATURES Table 4.0 Rv.1 ITEM #
DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD#
4.0-1 LAl CTS 5.1 CTS 5.1 provides descriptive details related to 2/10/97 Provide LA6 CTS 1.19 the plant location, the proximity to Unit 1, a additional LA2 and coal-fired generating plant, and a statement discussion and LA3 Figure related to the distance from the reactor center justification LA4 1.1-1 line to the site exclusion boundary.
for moving LA5 CTS 5.3 these details CTS 5.4 CTS 1.19 and Figure 1.1-1 describe details of to licensee CTS 5.2 the site boundary and are not retained in ITS controlled CTS 5.5 4.1 and are moved to licensee controlled documents.
documents.
CTS 5.3 provides descriptive details related to the Reactor Core and the Reactor Coolant System (RCS).
CTS 5.4 provides descriptive details related to the New and Spent Fuel Storage Racks.
CTS 5.2 provides descriptive details related to the Reactor Containment, Penetrations, and Containment Systems.
CTS 5.5 provides descriptive details related to seismic design of plant structures and systems.
The DOG discussions simply state that these details are moved followed by a generic statement without a sufficiently detailed discussion stating why the CTS requirements will be adequately controlled in the alternate location.
HBR ITS 4.0 DESIGN FEATURES Table 4.0 Rv.1 ITEM # DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed JFD#
4.0-2 M3 CTS CTS 5.4.2.1 and 5.4.2.2 specify limits on Kef.
2/10/97 Provide 5.4.2.1 ITS 4.3.1.1b and 4.3.1.2b add the requirement additional and for the inclusion of an uncertainty allowance discussion and 5.4.2.2 to these limits. The justification states that justification "the ITS specifies that uncertainties must be for this more accounted for in the criticality analysis," but restrictive does not reference where this requirement is change.
found.
4.0-3 No STS In adapting the CTS into the STS format, ITS 2/10/97 Provide JFD 4.3.1.1c, 4.3.1.1c, 4.3.1.1d, and 4.3.1.2d, add the justification 4.3.1.1d, nominal center-to-center spacing between fuel for the plant Ml and assemblies placed in the high and low density specific 4.3.1.2d spent fuel storage racks, and the new fuel spacing based storage racks, respectively. There is no on system similar CTS requirement. The justification for design and this change does not show the plant-specific operational 10.5 inch and the 21 inch spacings are within constraints, the bounds of the safety analysis.
showing the ITS spacings oanalyses.
4.0-4 none CTS The CTS markup shows that the nominal 4/10/97 Provide 5.3.1.3 enrichment is relocated.
ther sections of the additional CTS markup show this enrichment to be contained discussion and in ITS 4.3.1 and 4.3.1.2. Clarify this justification discrepancy.
for this change.
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HBR ITS 4.0 DESIGN FEATURES Table 4.0 Rv.1 ITEM #
DOC CTS/STS Description of Issue Date Date COMMENTS or LCO Opened Closed J F D #
4.0-5 LA3 CTS Fuel storage "secured location restrictions" 4/10/97 Provide 5.4.2.1 are details that are proposed for relocation.
additional Could this design feature, if altered or discussion and modified (e.g., by inadvertently storing fuel justification in these locations), result in a significant for this effect on safety?
change.
4.0-6 A4 5.4.2.1 CTS nominal U235 enrichment is stated as 4.96%
4/10/95 Revise the ITS 5.4.2.2
+/- 0.5 %. This is translated as 5.0% in the or provide an ITS. The ITS is not an equivalent weight % and appropriate cannot be justified as an administrative less change.
restrictive change discussion.
4.0-7 LA3 5.4.2.2 CTS requires minimum integral burnable absorber 4/10/97 Revise the ITS for fuel assemblies with maximum planar or provide an enrichments. This requirement is proposed to appropriate be relocated. Could this design feature, if less altered or modified (e.g., by failing to restrictive include burnable absorber), result in a change significant effect on safety?
discussion.
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