RNP-RA/12-0107, Response to Request for Additional Information Related to Changes Regarding Technical Specification (TS) 3.1.4 Rod Group Alignment Limits and TS 3.1.7 Rod Position Indication

Response to Request for Additional Information Related to Changes Regarding Technical Specification (TS) 3.1.4 Rod Group Alignment Limits and TS 3.1.7 Rod Position Indication

ML12310A085
Person / Time
Site:	Robinson
Issue date:	10/22/2012
From:	Wheeler S A Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/12-0107
Download: ML12310A085 (4)

Text

jProgress Energy 10 CFR 50.90 Serial: RNP-RA/12-0107 OCT 2 22012 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 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO CHANGES REGARDING TECHNICAL SPECIFICATION (TS) 3.1.4 ROD GROUP ALIGNMENT LIMITS AND TS 3.1.7 ROD POSITION INDICATION By letter to the U. S. Nuclear Regulatory Commission (NRC) dated June 8, 2012, (Agencywide Documents Access and Management System Accession No. ML 12172A260), Carolina Power and Light Company, now doing business as Progress Energy, submitted a license amendment request (LAR) for Technical Specifications (TS) changes regarding Sections 3.1.4, "Rod Group Alignment Limits," and TS 3.1.7, "Rod Position Indication" for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP).By NRC letter dated September 18, 2012, (ADAMS Accession No. ML12250A065) the NRC staff requested additional information needed to complete the review of the license amendment request. The additional information was requested by November 2, 2012, and is provided in the Attachment to this letter.This response to the NRC staff's request for additional information does not change the schedule requirements in the June 8, 2012 letter and does not impact the conclusions of either the No Significant Hazards Consideration Determination or the Environmental Consideration presented.

in the Enclosure to the June 8, 2012 letter for this LAR.In accordance with 10 CFR 50.91, a copy of this letter is being provided to the State of South Carolina.This document contains no new Regulatory Commitments.

If you have any questions concerning this matter, please contact Mr. Richard Hightower, Supervisor

-Licensing/Regulatory Programs at (843) 857-1329.Progress Energy Carolinas, Inc.Robinson Nuclear Plant 3581 West Entrance Road Hartsville, SC 29550 United States Nuclear Regulatory Commission Serial: RNP-RA/12-0107 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed On: L--oI6e -2 17..Sincerely, Sharon A. Wheeler Manager -Support Services -Nuclear SAW/sjg

Attachment:

Response to Request for Additional Information Regarding Technical Specification (TS) 3.1.4 Rod Group Alignment Limits and TS 3.1.7 Rod Position Indication cc: Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)Mr. V. M. McCree, NRC, Region II Ms. A. T. Billoch-Colon, NRC Project Manager, NRR Ms. F. E. Saba, NRC Project Manager, NRR NRC Resident Inspectors, HBRSEP Mr. A. Wilson, Attorney General (SC)

United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/12-0107 Page 1 of 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION (TS) 3.1.4 ROD GROUP ALIGNMENT LIMITS AND TS 3.1.7 ROD POSITION INDICATION By letter to the U.S. Nuclear Regulatory Commission (NRC) dated June 8, 2012 (Agencywide Documents Access and Management System Accession No. ML 12172A260), Carolina Power & Light Company (the licensee), doing business as Progress Energy Carolinas, Inc., submitted a license amendment request for Technical Specifications (TS) changes regarding TS Section 3.1.4 "Rod Group Alignment Limits," and TS Section 3.1.7 "Rod Position Indication" for the H. B. Robinson Steam Electric Plant, Unit NO.2. The NRC staff has been reviewing the submittal and has determined that additional information is needed to complete its review.NRC Question Page 5 of the enclosure to the licensee's June 8, 2012, letter indicated that during the "soak-time" periods, an individual rod position indicator (RPI)difference from the demand position indication could be a legitimate indication of a misaligned rod.Discuss the plant operating procedures that provide procedural guidance of diagnosing the actual malfunction of the control rod or RPI system, and show that the procedural guidance is sufficient for operators to differentiate between an actual malfunction of rod control or RPI system, and discuss the RPI differences from demand position indication attributed to thermal instabilities during the "soak-time" periods.Progress Energy Response There is sufficient procedural guidance in the plant operating procedures to differentiate between an actual malfunction of the rod control or rod position indication (RPI) system, and RPI differences from demand position indication attributed to thermal instabilities during rod movement.

Plant procedures provide guidance on diagnosing the symptoms of an actual equipment malfunction, which will continue to remain valid after the TS change. Operators will continue to operate and diagnose the equipment using these procedures.

United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/12-0107 Page 2 of 2 The proposed TS change is intended to reduce the operator burden of entering LCO action statements when it is clear that the deviation is related to thermal transient effects following rod movement.

Upon implementation of the proposed TS change, the existing procedures will be supplemented to provide additional guidance on when it is appropriate to invoke the one hour soak time.Plant procedures direct that the Plant Computer, also known as the Emergency Response Facility Information System (ERFIS), be used to monitor control rod positions.

The ERFIS top level Safety Parameters Display System (SPDS) Alarm Screen is a tool used for identification of degrading equipment or plant conditions prior to main control room alarms, or system transients.

The ERFIS rod misalignment program monitors rod alignments whenever the Reactor Trip Breakers are shut, and automatically prints out alarm related information concerning rod position deviation, misalignment, and overlap sequence every ten minutes when off-normal conditions exist. The use of the ERFIS programs to monitor control rod positions will not change due to implementation of the proposed TS changes.The reactor control system abnormal operating procedure provides a list of symptoms of a misaligned rod, stuck rod or Individual Rod Position Indication (IRPI) failure and the required operator response for each condition with direction that if there is any doubt as to IRPI failure or actual rod misalignment then rod misalignment is to be assumed. When operating above power levels listed in LCO action statements for which control rod misalignment may impact the validity of the safety analyses, Engineering Surveillance Test EST-145, Determination of Control Rod Position Using the Movable Incore Detector System, can be used to determine the position of a control rod. This procedure utilizes the Moveable Incore Detector System (MIDS)to determine the control rod position by measuring flux traces. These traces are reviewed to determine actual control rod position.

The symptom list of the abnormal procedure and the determination of actual control rod position from flux traces will not change due to implementation of the proposed TS changes.