ML062130637

License Amendment 208 Regarding Emergency Diesel Generator or Automatic Trips Bypass TS 3.8.1

ML062130637
Person / Time
Site:	Robinson
Issue date:	10/04/2006
From:	Mozafari B NRC/NRR/ADRO/DORL/LPLII-2
To:	Walt T Carolina Power & Light Co
Mozafari B, NRR/ADRO/DORL, 415-2020
References
TAC MC9209
Download: ML062130637 (9)

Text

October 4, 2006Mr. T. 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 OF AN AMENDMENT ON EMERGENCY DIESEL GENERATOR AUTOMATIC TRIPS BYPASS TS 3.8.1 (TAC NO. MC9209)

Dear Mr. Walt:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 208 to RenewedFacility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBR). This amendment changes the HBR Technical Specifications in response to your application dated November 30, 2005.The amendment revises the frequency of the emergency diesel generator automatic tripsbypass Surveillance Requirement 3.8.1.11 from 18 months to 24 months.A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in theCommission's biweekly Federal Register notice. Sincerely, /RA/ Brenda Mozafari, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-261

Enclosures:

1. Amendment No. 208 to DPR-23

2. Safety Evaluationcc w/enclosures: See next page

ML062130637*SE dated June 16, 2006 NRR-058OFFICELPLII-2/PMLPLII-2/PMLPLII-2/LAEEEB/BC*ITSB/BCOGCLPL2-2/BCNAMELRegnerBMozafariCSolaGWilsonTKobetzSHamrickLRaghavanDATE8/1/068/1/068/1/0606/16/06 07/28/068/1/0610/4/06 Mr. T. D. WaltH. B. Robinson Steam Electric Plant,Carolina Power & Light Company Unit No. 2 cc:

Steven R. CarrAssociate General Counsel - 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 CAROLINA POWER & LIGHT COMPANYDOCKET NO. 50-261H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 208Renewed License No. DPR-231.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Carolina Power & Light Company (thelicensee), dated November 30, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 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 defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied. 2.Accordingly, the license is amended by changes to the Technical Specifications, asindicated in the attachment to this license amendment; and paragraph 3.B. of Renewed Facility Operating License No. DPR-23 is hereby amended to read as follows:B. Technical SpecificationsThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 208, 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/ L. Raghavan, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical SpecificationsDate of Issuance: October 4, 2006 ATTACHMENT TO LICENSE AMENDMENT NO. 208 RENEWED FACILITY OPERATING LICENSE NO. DPR-23DOCKET NO. 50-261Replace page 3 of Operating License No. DPR-23 with the attached page 3.Replace the following page of the Appendix A Technical Specifications with the attachedrevised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change. Remove PageInsert Page3.8-93.8-9 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 208 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 November 30, 2005, Carolina Power & Light Company, the licensee, proposedan amendment to the Technical Specification (TS) 3.8.1 contained in Appendix A of theOperating License No. DPR-23 for H. B. Robinson Steam Electric Plant (HBR). The proposed amendment revises the frequency of the emergency diesel generator (EDG) automatic tripsbypass Surveillance Requirements (SR) 3.8.1.11 from 18 months to 24 months. Currently, thelicensee performs the EDG inspection/maintenance at a frequency of 24 months. The proposed change will allow the licensee to schedule the EDG trips bypass testing at the sametime as the EDG inspection/maintenance.

2.0 REGULATORY EVALUATION

The regulatory requirements that the staff applied in its review of the application include:General Design Criterion (GDC) 17, "Electric power systems," of Appendix A, "General DesignCriteria for Nuclear Power Plants," to Title10 of the Code of Federal Regulations (10 CFR)Part 50, requires, in part, that nuclear power plants have onsite and offsite electric power systems to permit the functioning of structures, systems, and components that are important tosafety. The onsite system is required to have sufficient independence, redundancy, andtestability to perform its safety function, assuming a single failure. GDC 18, "Inspection and testing of electric power systems," requires the electric power systemsthat are important to safety be designed to permit appropriate periodic inspection and testing.As required by 10 CFR 50.36(c)(3), "Surveillance Requirements," the SRs relating to test,calibration, or inspection to assure that the necessary quality of systems and components ismaintained, that facility operation will be within safety limits, and that the limiting conditions foroperation will be met.Regulatory Guide 1.9, "Selection, Design, Qualification, and Testing of Emergency DieselGenerator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plants,"

Rev. 3, Section 1.8, states that the EDG unit should be automatically tripped on an engineoverspeed and generator-differential overcurrent (critical trips). It further states that other trips

- 2 -(non-critical) should be handled in one of the two ways: (1) a trip should be implemented withtwo or more measurements for each trip parameter with coincident logic provisions for trip actuation, or (2) a trip may be bypassed under accident conditions provided the operator has sufficient time to react appropriately to an abnormal EDG unit condition.

3.0 TECHNICAL EVALUATION

Presently, SR 3.8.1.11 requires verification that each EDG's non-critical automatic trips (e.g., coolant water temperature high, crank case pressure high, coolant pressure low, and lube oil pressure low) are bypassed except the engine overspeed (critical trip), at a frequency of 18 months. The licensee has proposed to revise the frequency of SR 3.8.1.11 from 18 months to 24 months.The licensee carries out the EDG inspection during the plant operation by utilizing Condition Bof Limiting [Condition for Operation] LCO 3.8.1, which requires restoration of an inoperableEDG within 7 days. During this period, the EDG inspection (maintenance and testing) is conducted. The licensee stated that in 2002, a change from an 18 month to a 24 monthinspection frequency for DG inspection was adopted for HBR as recommended by the Fairbanks-Morse Owners Group. The performance of SR 3.8.1.11 (every 24 months) during the EDG inspection outage is preferred because the EDG is already unavailable for the other required maintenance and testing (also called overhaul).SR 3.8.1.11 demonstrates that the EDG non-critical automatic trips are bypassed except theengine overspeed (critical trip). At HBR, the non-critical trips are bypassed simply by changing the position of a manual key-operated bypass switch to the "Trips Defeat" position, which opens the stop relay circuit of the engine. A control room alarm "EDG trouble" is annunciated if the switch is placed in the "Trips in Service" position. The non-critical trips are bypassed during design basis accidents by simply keeping the manual bypass switch in "Trips Defeat" position.

The SR is satisfied by simulating a trip signal to each of the four non-critical trips by placing a jumper in the actuation circuit and observing the EDG does not receive a trip signal. The "EDG trouble" alarm is also annunciated on any abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The licensee provided the following to justify that the proposed frequency change from18 months to 24 months will not affect the reliability of the trip bypass circuit of emergencyEDGs:A review of maintenance and testing records showed that there were no failuresof the trip bypass circuitry. This result is not unexpected because of the simplicity of this circuitry. The trip bypass is a key-switch that is placed in the "Trips Defeat" position, which opens the only circuit path that can automaticallyenergize the Stopping Relay. This test is fundamentally a verification that the key-switch creates the open circuit, thus preventing the non-critical trips.Considering the licensee's past experience, the NRC staff agrees that changing the frequencyof SR 3.8.1.11 from 18 months to 24 months will not impact the reliability of trip bypass circuit of emergency EDGs. According to TSs of some other nuclear plants (such as Brunswick, Calvert Cliffs, Diablo Canyon), the frequency of SR for verification of the EDG non-critical automatic trips bypass is also 24 months.

- 3 -

4.0 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.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes the Surveillance Requirements. The NRC staff has determi ned thatthe amendment involves no significant increase in the amounts, and no significant change inthe types, of any effluents that may be released offsite, and that there is no significant increasein 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 (71 FR 10072). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmentalassessment need be prepared in connection with the issuance of the amendment.

6.0 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: Vijay Goel Date: October 4, 2006