ML053220007

Issuance of Amendment Extension of Containment Air Lock Interlock Surveillance Requirement Interval (Tac No. MC5779)

ML053220007
Person / Time
Site:	Seabrook
Issue date:	01/06/2006
From:	Geoffrey Miller Plant Licensing Branch III-2
To:	St.Pierre G Florida Power & Light Energy Seabrook
Miller G, NRR/DLPM, 415-2481
References
TAC MC5779
Download: ML053220007 (12)

Text

January 6, 2006 Mr. Gene F. St. Pierre, Site Vice President c/o James M. Peschel Seabrook Station FPL Energy Seabrook, LLC PO Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT RE: EXTENSION OF CONTAINMENT AIR LOCK INTERLOCK SURVEILLANCE REQUIREMENT INTERVAL (TAC NO. MC5779)

Dear Mr. St. Pierre:

The Commission has issued the enclosed Amendment No. 106 to Facility Operating License (FOL) No. NPF-86 for Seabrook Station, Unit No. 1 (Seabrook). This amendment is in response to your written request dated January 10, 2005. The amendment revises the Seabrook Technical Specifications (TSs) to extend the required interval for performance of Containment Air Lock Interlock Surveillance Requirement 4.6.1.3 from 6 months to 24 months.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

G. Edward Miller, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosures:

1. Amendment No. 106 to FOL No. NPF-86

2. Safety Evaluation cc w/encls: See next page

Seabrook Station, Unit No. 1 cc:

Mr. Peter Brann Mr. Stephen McGrail, Director Assistant Attorney General ATTN: James Muckerheide State House, Station #6 Massachusetts Emergency Management Agency Augusta, ME 04333 400 Worcester Road Framingham, MA 01702-5399 Resident Inspector U.S. Nuclear Regulatory Commission Philip T. McLaughlin, Attorney General Seabrook Nuclear Power Station Steven M. Houran, Deputy Attorney P.O. Box 1149 General Seabrook, NH 03874 33 Capitol Street Concord, NH 03301 Town of Exeter 10 Front Street Mr. Bruce Cheney, Director Exeter, NH 03823 New Hampshire Office of Emergency Management Regional Administrator, Region I State Office Park South U.S. Nuclear Regulatory Commission 107 Pleasant Street 475 Allendale Road Concord, NH 03301 King of Prussia, PA 19406 Mr. M. S. Ross, Managing Attorney Office of the Attorney General Florida Power & Light Company One Ashburton Place, 20th Floor P.O. Box 14000 Boston, MA 02108 Juno Beach, FL 33408-0420 Board of Selectmen Mr. Rajiv S. Kundalkar Town of Amesbury Vice President - Nuclear Engineering Town Hall Florida Power & Light Company Amesbury, MA 01913 P.O. Box 14000 Juno Beach, FL 33408-0420 Ms. Deborah Bell Federal Emergency Management Agency James M. Peschel Region I Regulatory Programs Manager J.W. McCormack P.O. & Seabrook Station Courthouse Building, Room 401 FPL Energy Seabrook, LLC Boston, MA 02109 PO Box 300 Seabrook, NH 03874 Mr. Tom Crimmins Polestar Applied Technology One First Street, Suite 4 Los Altos, CA 94019

Seabrook Station, Unit No. 1 cc:

David Moore Vice President, Nuclear Operations Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi Senior Attorney Florida Power & Light Company 801 Pennsylvania Ave., NW Suite 220 Washington, DC 20004

Mr. Gene F. St. Pierre, Site Vice President c/o James M. Peschel Seabrook Station FPL Energy Seabrook, LLC PO Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT RE: EXTENSION OF CONTAINMENT AIR LOCK INTERLOCK SURVEILLANCE REQUIREMENT INTERVAL (TAC NO. MC5779)

Dear Mr. St. Pierre:

The Commission has issued the enclosed Amendment No. 106 to Facility Operating License (FOL) No. NPF-86 for Seabrook Station, Unit No. 1 (Seabrook). This amendment is in response to your written request dated January 10, 2005. The amendment revises the Seabrook Technical Specifications (TSs) to extend the required interval for performance of containment Air Lock Interlock Surveillance Requirement 4.6.1.3 from 6 months to 24 months.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

G. Edward Miller, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosures:

1. Amendment No. 106 to FOL No. NPF-86

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC DRoberts RDennig DORL DPR GMatakas, RGN-I LPL1-2 R/F GEMiller JPulsipher GHill (2)

CHolden CRaynor ACRS OGC Accession Number: ML053220007 OFFICE LPL1-2/PM: CM LPL1-2/LA SPSB-A/SC OGC LPL1-2/BC NAME GEMiller CRaynor RDennig JBonanno DRoberts DATE 12/07/05 12/07/05 10/27/2005 12/15/05 12/22/05 OFFICIAL RECORD COPY

FPL ENERGY SEABROOK, LLC, ET AL.*

DOCKET NO. 50-443 SEABROOK STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 106 License No. NPF-86

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by FPL Energy Seabrook, LLC, et al. (the licensee), dated January 10, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (I) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

• FPL Energy Seabrook, LLC (FPLE Seabrook) is authorized to act as agent for the following:

Hudson Light & Power Department, Massachusetts Municipal Wholesale Electric Company, and Taunton Municipal Light Plant. FPLE Seabrook has exclusive responsibility and control over the physical construction, operation and maintenance of the facility.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-86 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 106, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Darrell J. Roberts, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License Date of Issuance: January 6, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 106 FACILITY OPERATING LICENSE NO. NPF-86 DOCKET NO. 50-443 Replaced the following page of the Appendix A, Technical Specifications, with the attached revised page as indicated. The revised page is identified by amendment number and contains marginal lines indicating the area of change.

Remove Insert 3/4 6-8 3/4 6-8

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 106 TO FACILITY OPERATING LICENSE NO. NPF-86 FPL ENERGY SEABROOK, LLC SEABROOK STATION, UNIT NO. 1 DOCKET NO. 50-443

1.0 INTRODUCTION

By letter dated January 10, 2005, FPL Energy Seabrook, LLC (FPLE or the licensee) submitted License Amendment Request (LAR) No. 04-07, requesting changes to the Technical Specifications (TSs) for Seabrook Station, Unit No. 1 (Seabrook).

The proposed revision would revise the Seabrook TSs to extend the required interval for performance of the Containment Air Lock Interlock Surveillance Requirement (SR) 4.6.1.3 from 6 months to 24 months.

The Nuclear Regulatory Commission (NRC or the Commission) staffs proposed no significant hazards consideration determination was published in the Federal Register on May 24, 2005 (70 FR 29796).

2.0 REGULATORY EVALUATION

Appendix A to Title 10 of the Code of Federal Regulations (10 CFR), Part 50, General Design Criteria for Nuclear Power Plants, contains the following pertinent criteria:

Criterion 16, Containment Design states:

Reactor containment and associated systems shall be provided to establish an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment and to assure that the containment design conditions important to safety are not exceeded for as long as postulated accident conditions require.

Criterion 53, Provisions for Containment Testing and Inspection states:

The reactor containment shall be designed to permit (1) appropriate periodic inspection of all important area, such as penetrations, (2) an appropriate surveillance program, and (3) periodic testing at containment design pressure of the leaktightness of penetrations which have resilient seals and expansion bellows.

In accordance with the requirement of Criterion 16 for an essentially leak-tight containment barrier, containment air locks are designed with interlocks on the doors so that both doors may not be open at the same time.

In accordance with the requirement of Criterion 53 for containments to be designed to permit appropriate periodic inspection of all important areas (such as penetrations) and an appropriate surveillance program, plant TSs require periodic testing of the interlock mechanism to assure that both doors cannot be opened at the same time.

There is no regulatory requirement that specifies the interval between tests. The Improved Standard Technical Specifications (ISTS) for Westinghouse Plants (NUREG-1431), Revision 3, provide for a 24-month interval. Earlier revisions provided for a 6-month interval. This interval was revised following NRC approval of the Technical Specification Task Force, Improved Standard Technical Specifications Change Traveler 17-A, Revision 2 (TSTF-17-A, Rev. 2) on November 2, 1999.

3.0 TECHNICAL EVALUATION

3.1 Introduction The Seabrook containment building has two air locks for personnel ingress and egress. Normal access is through the personnel hatch air lock. The second air lock is mainly for emergency egress and is part of the containment building equipment hatch. The air locks are designed with an inner and outer door, each sufficient to provide a leak-tight barrier rated to withstand the maximum expected post-accident containment pressure. Closure of either door will support containment operability. Regardless, both doors are generally maintained closed when the air lock is not being used for normal entry into or exit from the containment building.

The personnel hatch air lock is designed with two interlocks, one mechanical and one electrical, which serves as a backup to the mechanical. Either interlock, however, may be used as the sole interlock to meet the TS 3.6.1.3 requirement. The equipment hatch air lock is designed with a mechanical interlock only. In addition, limit switches for each door provide control room indication of door position. During periods when containment is not required to be operable, the door interlock mechanism(s) may be disabled, allowing both doors of an air lock to remain open for extended periods, when frequent containment entry is necessary. Station procedures control the disabling and re-enabling of the interlocks.

3.2 Generic Revision to the ISTS TSTF-17-A, Rev. 2, provided the following justification for the extension of the SR interval:

Typically, the interlock is installed after each refueling outage, verified operable with this surveillance and not disturbed until the next refueling outage. If the need for maintenance arises when the interlock is required, the performance of the interlock surveillance would be required following the maintenance. In addition, when an air lock is opened during times the interlock is required, the operator first verified that one door is completely shut and the door seals pressurized before attempting to open the other door. Therefore, the interlock is not challenged except during actual testing of the interlock. Consequently, it

should be sufficient to ensure proper operation of the interlock by testing the interlock on a 24-month interval.

Testing of the airlock interlock mechanism is accomplished through having one door not completely engaged in the closed position, while attempting to open the second door. Failure of this surveillance effectively results in a loss of containment integrity. Procedures and training do not allow this interlock to be challenged for ingress and egress. One door is opened, all personnel and equipment as necessary are placed into the airlock and then the door is completely closed prior to attempting to open the second door. This surveillance is contrary to processes and training of conservative operation when the interlock function is required. The door interlock mechanism cannot be readily bypassed, linkages must be removed which are under the control of station processes such as temporary modifications, containment closure procedures, and out-of-service practices. The failure rate of this physical device is very low based on the design of the interlock.

Historically, this interlock verification has had its frequency chosen to coincide with the frequency of the overall airlock leakage test. According to 10 CFR 50, Appendix J, Option A, this frequency is once per 6 months. However, Appendix J, Option B, allows for an extension of the overall leakage test frequency to a maximum of 30 months.

For the above reasons, it is proposed to change the required frequency for the surveillance to 24 months (and, with the allowance of SR 3.0.2, this provides a total of 30 months, which corresponds to the overall air lock leakage test frequency under Option B). In this fashion, the interlock can be tested in a mode where the interlock is not required.

In NUREG-1431, Revision 3, the basis for the interlock SR states:

Periodic testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due to the purely mechanical nature of this interlock, and given that the interlock mechanism is not normally challenged when the containment air lock door is used for entry and exit (procedures require strict adherence to single door opening), this test is only required to be performed every 24 months. The 24-month frequency is based on the need to perform this surveillance under the conditions that apply during a plant outage, and the potential for loss of containment OPERABILITY if the surveillance were performed with the reactor at power. The 24-month frequency for the interlock is justified based on generic operating experience. The 24-month frequency is based on engineering judgement and is considered adequate given that the interlock is not challenged during the use of the airlock.

3.3 Revision to the Seabrook TSs

In general, the Seabrook TSs and physical configuration are in accordance with the considerations contributing to the approval of the generic revision to the ISTS. However, prior to 1998, Seabrook experienced problems with the mechanical interlock cables (a set of two) and attachments associated with the personnel hatch air lock. Following several modifications and eventual replacement of one original cable with a new design in 1998, reliability of the cable improved resulting in no signs of failure over the subsequent six years. Despite the cable problems, no interlock surveillance test itself had failed from January 1990 until March 2004. In March 2004, the other cable (old style, original) on the personnel hatch air lock experienced the same failure and was replaced with a similar cable of new design. The licensee expects the recently replaced cable to perform as well as the other cable of new design that was installed in 1998. The cables associated with the mechanical interlock for the personnel hatch air lock are easily accessible for visual inspection and are inspected during the interlock test to note any degradation. In addition, to ensure early detection for signs of cable degradation between surveillance tests, a preventative maintenance procedure is being developed to periodically inspect the cables for both air locks on a more frequent basis. The personnel hatch air lock interlock cables are being inspected more frequently due to the more frequent use of the air lock as the primary access point for ingress and egress of the containment building.

The equipment hatch air lock has never experienced a mechanical interlock failure and every interlock surveillance test since January 1990 has passed satisfactorily.

Given the alignment with the generically-approved ISTS revision, TSTF-17-A, Rev. 2, and the historic reliability of the containment air lock interlocks, the NRC staff finds the proposed revision to the Seabrook TSs to be acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the New Hampshire and Massachusetts State officials were notified of the proposed issuance of the amendment. The State officials had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in 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 (70 FR 29796). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment 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) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: J. Pulsipher Date: January 6, 2006