ML021070698

Response to Request for Additional Information Re License Amendment Request 01-07

ML021070698
Person / Time
Site:	Seabrook
Issue date:	04/08/2002
From:	Feigenbaum T North Atlantic Energy Service Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR-01-07, NYN-02038
Download: ML021070698 (6)

Text

North Atlantic Energy Service Corporation P.O. Box 300 SNotSeabrook, NH 03874 Atlantic (603) 474-9521 The Northeast Utilities System April 8, 2002 Docket No. 50-443 NYN-02038 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-001 Seabrook Station Response to Request for Additional Information Regarding License Amendment Request 01-07, "Changes to Certain Technical Specifications Associated with Response Time Testing"

References:

1)

North Atlantic letter to NRC (NYN 02035) Response to Request for Additional Information Regarding License Amendment Request 01-07, "Changes to Certain Technical Specifications Associated with Response Time Testing& " dated March 25, 2002.

2)

North Atlantic letter to NRC (NYN-0 1105) License Amendment Request (LAR) 01 07, "Changes to Certain Technical Specifications Associated with Response Time Testing," dated December 21, 2001.

Based upon discussions that occurred during a telephone conference held on April 3, 2002, with regard to LAR 01-07, North Atlantic Energy Service Corporation (North Atlantic) is providing the following clarifications and corrections.

The NRC SER associated with WCAP-13632-P-A requires North Atlantic to provide a response time for those Rosemount gage and differential pressure transmitters that did not have published response times. In the RAI response letter, dated March 25, 2002, North Atlantic stated that plant historical data was used as the basis for the LAR published response times. Additionally, North Atlantic stated that the conclusions from the historical data review were further verified against Rosemount publications for consistency.

A001

U.S. Nuclear Regulatory Commission NYN-02038/ Page 2 As a result of further review, North Atlantic will use the published Rosemount response times as the basis for the LAR response times noted on Tables I.B-1 and I.B-2 for these transmitters. This revised basis does not change any of the response time values previously documented in LAR 01-07.

The Rosemount response times may be found in the following manufacturer's publications, which were previously provided to the NRC by letter dated March 25, 2002:

"* Rosemount Publication 00813-0100-4302, R/AB, 1999, Model 1153DB5

& GB9 Specification Section: Response Time for Range Code 5 & 9 = 0.200 seconds.

"* Rosemount Publication 00813-0100-4514, R/AA, 1999, Model 1154GP9

& DP4 Specification Section: Response Time for Range Code 9 = 0.200 seconds and for Range Code 4 = 0.500 seconds.

In addition, North Atlantic's RAI response letter, dated March 25, 2002 contained an update to Table I.B-1 and I.B-2 in LAR 01-07.

In the revised tables, sensor types were identified in response to RAI question #4. Table I.B-2 listed one sensor for Steam Line Hi Negative Rate when in fact three different types of sensors are installed for this ESFAS Function. In addition to this clarification, the 0.400 second sensor response time as originally listed should have been listed as 0.200 seconds. A revision to this table is attached to this letter.

The 7300 Process Cabinet string times listed on Tables I.B-1 and I.B-2 follow the methodology of WCAP-14036 as described in section 8.0 "Program Methodology." The response times listed in the Tables of the North Atlantic LAR reflect generic string response times as listed in Table 8-1 of WCAP-14036 and SER Table 1. In developing the listed response times for Westinghouse 7300 Process Cabinet strings, a time allocation was not provided for lead/lag cards. As described in WCAP-14036, Section 4.0, the dynamic response of lead-lag functions is tested (i.e., calibrated) as part of the periodic channel surveillance calibration and, therefore, the card response time does not have to be verified independently by other tests. To clearly identify this position, North Atlantic has added a note to Tables I.B-1 and I.B-2. The note is applicable to the listing of response times for the 7300 Process Cabinet String and states "Listed response times do not provide an allowance for lead/lag cards when installed in 7300 Process Cabinet strings."

Basing response time testing on the values contained in the aforementioned WCAPs does not change the conclusions of the original LAR 01-07 submittal, that the proposed change does not involve a significant hazard consideration pursuant to 10CFR50.92, and still meets the criteria of 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

U.S. Nuclear Regulatory Commission NYN-02038/ Page 3 Should you have any questions regarding this letter, please contact Mr. James M. Peschel, Manager - Regulatory Programs, at (603) 773-7194.

Very truly yours, NORTH ATLANTIC ENERGY SERVICE CORP.

Ted C. FeigenbailK Executive Vice President and Chief Nuclear Officer cc:

H. J. Miller, NRC Region I Administrator R.D. Starkey, NRC Project Manager, Project Directorate 1-2 G. F. Dentel, NRC Senior Resident Inspector

ATTACHMENT 1 TO NYN-02038

TABLE I.B-1 Reactor Trip System (RTS) Response Time Allocations RTS Function Sensor Type (Sec 7300 Process Cabinet (Note 7)

.)

String (Sec.)

SSPS Input Relay / Loaic (Note 1)

(Sec.)

NIS PR High & Low SP NIS PR High Positive Rate NIS PR High Negative Rate OTAT, OPAT / Tavg Pressurizer Pressure Low & High Reactor Coolant Flow Low S/G Level Low-Low RCP Undervoltage RCP Underfrequency (Note 2)

(Note 2)

(Note 2)

(Note 5)

Rosemount 1154 GP9 Westinghouse Veritrak 76 DPI &

Tobar 32 DP2 Rosemount 1154 DP4 (Note 6)

(Note 6)

(Note 2)

NIS cabinet (Note 3)

(Note 2)

NIS cabinet (Note 4)

(Note 2)

NIS cabinet (Note 3)

(Note 5)

NRA+NSA+

NSA+NSA+

NAL 0.200 NLP+NAL 0.400 NLP+NAL 0.500 (Note 6)

(Note 6)

NLP+NAL 0.065 0.020 / 0.01 0.300 0.020/0.01 0.200 0.020 / 0.01 0.400 0.020 / 0.01 0.100 0.020/0.01 0.100 0.020/0.01 0.100 0.020/0.01 For the Input Relays, the response time allocation is 0.020 sec. for normally energized relays.

Nuclear Instrumentation detectors are not response time tested.

Westinghouse Nuclear Instrumentation Cabinet time allocation from WCAP-14036-P-A, Revision 1 (Reference 2).

Westinghouse Nuclear Instrumentation Cabinet time allocation from Seabrook Station Plant Data.

Periodic response time testing of the Resistance Temperature Detectors (RTDs) will continue.

Periodic response time testing of these functions will continue.

Listed response times do not provide an allowance for lead/lag cards when installed in 7300 Process Cabinet strings.

Notes:

1.

2.

3.

4.

5.

6.

7.

TABLE I.B-2 Engineered Safety Features Actuation System (ESFAS) Response Time Allocations ESFAS Function Sensor 7300 Process SSPS Input Cabinet Relay / Logic (Note 3)

(Note 1)

Type (Sec.)

String (Sec.)

Containment Pressure HI-I Pressurizer Pressure Low Steam Pressure Low Containment Pressure HI-3 Containment Pressure HI-2 Steam Line Hi Negative Rate S/G Level HI-HI S/G Level Low-Low Emergency Feedwater Flow RWST Level Low-Low LOP Diesel Generator Start CBA Actuation on Control Room HI Radiation Notes:

Westinghouse Barton 752 Rosemount 1154 GP9 Westinghouse Veritrak 76 PG1, Tobar 32 PA2, Rosemount 1153 GB9 Westinghouse Barton 752 Westinghouse Barton 752 Westinghouse Veritrak 76 PG1, Tobar 32 PA2, Rosemount 1153 GB9 Rosemount 1154 DP4 Rosemount 1154 DP4 Rosemount 1153 DB5 Westinghouse Veritrak 76 DPI (Note 2)

(Note 2) 0.400 0.200 0.200 0.400 0.400 0.200 0.500 0.500 0.200 0.400 (Note 2)

(Note 2)

(Sec.)

NLP & NAL 0.100 NLP & NAL 0.100 NLP & NAL 0.100 NLP & NAL 0.100 NLP & NAL 0.100 NLP & NAL 0.100 NLP & NAL 0.100 NLP & NAL 0.100 (Note 2)

NLP & NAL 0.100 For the Input Relays, the response time allocation is 0.020 sec. for normally energized relays, and 0.026 sec. for normally de-energized relays.

Periodic response time testing of these functions will continue.

Listed response times do not provide an allowance for lead/lag cards when installed in 7300 Process Cabinet strings.

7 0.020/0.01 0.020 / 0.01 0.020 / 0.01 0.026 / 0.01 0.020 / 0.01 0.020 / 0.01 0.020 / 0.01 0.020/0.01 0.026 / 0.01

1.

2.

3.