ML031620506
| ML031620506 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/30/2003 |
| From: | Warner M Florida Power & Light Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NYN-03037 | |
| Download: ML031620506 (8) | |
Text
FPL Energy FPL Energy Seabrook Station Seabrook Station P.o. Box 300 Seabrook, NH 03874 (603) 773-7000 May 30,2003 Docket No. 50-443 NYN-03037 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
References:
- 1.
NYN-02089, "Changes to TS 3.9.4 Containment Building Penetrations," dated October 11, 2002.
- 2.
NYN-03043, "Revision to License Amendment Request 02-07, Changes to TS 3.9.4 Containment Building Penetrations," dated May 30, 2003.
Seabrook Station Responses to Requests for Information The FPL Energy Seabrook, LLC responses to the Nuclear Regulatory Commission requests for additional information issued on March 13, 2003 and on April 17, 2003 are provided in Enclosures 1 and 2 of this letter respectively. The information requested pertains to a license amendment requested on October 11, 2002 regarding a change to Technical Specification 3.9.4, Containment Penetrations.
Should you have any questions concerning this response, please contact Mr. James Peschel, Regulatory Programs Manager, at (603) 773-7194.
Very truly yours, FPL Energy Seabrook, LLC Mark E. Warner Site Vice President cc:
H. J. Miller, NRC Region I Administrator V. Nerses, NRC Project Manager, Project Directorate 1-2 G. T. Dentel, NRC Senior Resident Inspector 5O DI
Oath and Affirmation L Mark E. Warner, Site Vice President of FPL Energy Seabrook, LLC, hereby affirm that the information and statements contained within this document are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
Sworn and Subscribed before me this 3° dayof m7ay 2003 Mark E. Warner Site Vice President z
- -7
ENCLOSURE 1 TO NYN-03037
Based on the Seabrook Station submittal dated October 11, 2002, the NRC requested the following additional information in a request dated March 13, 2003:
Request A:
It is unclearfrom the submittal as to how the containment outage door is opened and closed. If electrically powered equipment is required to open and close the containment outage door, then TSTF-441 Comments 1 above is applicable. Provide any additional commitments, controls, and analyses that would address this concern.
Response
This request is no longer applicable. LAR 02-07 has been revised to incorporate the guidance identified in TSTF-5 1. Refer to Reference 2.
Request B:
The submittal does not address the concern discussed in TSTF-441 Comment 2 above.
This information needs to be provided and should be included as part of the Bases discussion.
Response
This request is no longer applicable. LAR 02-07 has been revised to incorporate the guidance identified in TSTF-51. As a result of the revision to LAR 02-07, FPLE Seabrook will implement the provisions of Section 11.3.6.5 of NUMARC 93-01, Rev. 03 guidelines on restoration capability for containment systems as recommended in TSTF-51.
Request C:
The October 11, 2002, submittal states that the containment outage door can be closed within one (1) hour. Based on the discussion in TSTF-441 Comment 3 above, there is no commitment or assurance that the containment outage door will be closed within one (1) hour and a justifcation that this one (1) hour closure time is a acceptable closure time.
Provide this information.
Response
This request is no longer applicable. LAR 02-07 has been revised to incorporate the guidance identified in TSTF-5 1. Refer to Reference 2.
Request D:
The October 11, 2002, submittal does not address the concern discussed in TSTF-441 Comment 4. Provide this information, and discuss why the calculated dose is acceptable.
Response
This request is no longer applicable.
LAR 02-07 has been revised to incorporate the guidance identified in TSTF-5 1. Refer to Reference 2.
Request E:
Based on TSTF-441 Comments I thru 4 as supplemented by the above requests for additional information A through D, and the discussion in STF-441 Comment 5, the licensee should consider revising the proposal to implement TSTF-51 rather than its current proposal which is similar to TSTF-441.
Response
LAR 02-07 has been revised to incorporate the guidance identified in TSTF-51 as recommended. Refer to Reference 2.
ENCLOSURE 2 TO NYN-03037
Based on the Seabrook Station submittal dated October 11, 2002, the NRC requested the NRC requested the following additional information in a request dated April 17, 2003:
Request 1:
On page 6 of the Introduction and Safety Assessment of Proposed Changes, "the submittal states that the most limiting time to boil after a loss of RHR cooling with at least 23 feet of water above the vesselflange, the upper internals removed, and after 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of decay time is approximately 8.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Section B of the Introduction and Safety Assessment of Proposed Changes, " states that "Removing or reinstalling the containment equipment hatch is a lengthy evolution that requires approximately one shift to complete. " The staff understands that a shif is approximately 8-12 hours. This last statement appears to be in conflict with TS 3.9.8.1 and TS 3.9.8.2 which, according to the submittal, requires that all containment penetrations with direct access from the containment atmosphere to outside atmosphere must be closed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in the case of a loss of RHR cooling Based on the conflicting information above, the staff is concerned that the containment equipment hatch may not be closed prior to boiling in the case of a loss of RHR cooling. Verify that the containment equipment hatch can be closed prior to boiling in the case of a loss of RHR cooling.
Response
The proposed license amendment is not in conflict with TS 3.9.8.1 and 3.9.8.2. As presently written, TS 3.9.4.a requires that the equipment [hatch] door be closed and held in place by a minimum of four bolts during core alterations or movement of irradiated fuel within the containment. When the plant is in a condition with the cavity level greater than or equal to 23 feet (TS 3.9.8.1), the proposed license amendment will permit the containment outage door (capable of being closed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) to be used for containment closure in lieu of the equipment hatch door. During refueling operations with reactor cavity level less than 23 feet (TS 3.9.8.2), the proposed containment outage door will not be relied upon to meet the requirements of TS 3.9.4.a.
Request 2:
The intent of the proposed wording for LCO 3.9.4b is not clear. As proposed, the LCO would state:
"A minimum of one door in each airlock or the containment outage door is capable of being closed, is closed, however both doors of one personnel airlock may be open if.... "
The Note states "This requirement does not apply to the equipment hatch air lock when the containment outage door is installed. "
The staff considers that the statement "...or the containment outage door is capable of being closed. " is unnecessary and confusing. If according to the proposed Note, LCO 3.9.4b is not applicable to the equipment hatch airlock when the outage door is installed, what is the purpose of the above statement? The staff believes that the proposed LCO 3.9.4b could be interpreted as a minimum of one door of the containment personnel airlock does not need to be closed if the containment outage door is installed.
Response
The subject footnote has been removed from revision 1 of LAR 02-07.
Refer to Reference 2.