ML063050698

Request for Additional Information Regarding License Amendment Request for Miscellaneous Technical Specification Changes

ML063050698
Person / Time
Site:	Seabrook
Issue date:	11/22/2006
From:	Geoffrey Miller NRC/NRR/ADRO/DORL/LPLI-2
To:	St.Pierre G Florida Power & Light Energy Seabrook
Miller G, NRR/DLPM, 415-2481
References
TAC MD2791
Download: ML063050698 (5)

Text

November 22, 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:

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR MISCELLANEOUS TECHNICAL SPECIFICATION CHANGES (TAC NO. MD2791)

Dear Mr. St. Pierre:

By letter dated August 7, 2006, FPL Energy Seabrook, LLC submitted license amendment request (LAR) 06-03. The LAR requested to revise various sections of the Seabrook Station, Unit No. 1 Technical Specifications (TSs). This letter relates specifically to the changes proposed for TS 3.3.9, Remote Shutdown System, and TS 3.7.4, Service Water System/Ultimate Heat Sink.

The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review. These questions were discussed with Mr. Michael OKeefe of your staff on October 12, 2006.

In order to complete our review of LAR 06-03 in a timely manner, a response to this request for additional information is required to be provided within 45 days. If you cannot respond within 45 days, please inform us in writing why you cannot response and provide an alternate response date. This alternate response date must be no later than 60 days from the date of this letter.

Please note that if you do not respond to this letter within 45 days or provide an acceptable alternate date in writing, we may reject your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If you have any questions, I can be reached at (301) 415-2481.

Sincerely,

/RA Richard Ennis for/

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

Enclosure:

Request for Additional Information cc w/encl: See next page

November 22, 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:

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR MISCELLANEOUS TECHNICAL SPECIFICATION CHANGES (TAC NO. MD2791)

Dear Mr. St. Pierre:

By letter dated August 7, 2006, FPL Energy Seabrook, LLC submitted license amendment request (LAR) 06-03. The LAR requested to revise various sections of the Seabrook Station, Unit No. 1 Technical Specifications (TSs). This letter relates specifically to the changes proposed for TS 3.3.9, Remote Shutdown System, and TS 3.7.4, Service Water System/Ultimate Heat Sink.

The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review. These questions were discussed with Mr. Michael OKeefe of your staff on October 12, 2006.

In order to complete our review of LAR 06-03 in a timely manner, a response to this request for additional information is required to be provided within 45 days. If you cannot respond within 45 days, please inform us in writing why you cannot response and provide an alternate response date. This alternate response date must be no later than 60 days from the date of this letter.

Please note that if you do not respond to this letter within 45 days or provide an acceptable alternate date in writing, we may reject your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If you have any questions, I can be reached at (301) 415-2481.

Sincerely,

/RA Richard Ennis for/

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

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

PUBLIC RidsNrrDorlLpl1-2 RidsNrrPMGMiller RidsOgcMailCenter LPL1-2 R/F RidsNrrLACRaynor RidsAcrsAcnwMailCenter JTatum RidsNrrDssSbpb ADAMS Accession Number: ML063050698 OFFICE LPL1-2/PM LPL1-2/LA DSS/SBPB/BC LPL1-2/BC NAME GEMiller CRaynor JSegala Hchernoff (REnnis for)

DATE 11/14/2006 11/14/2006 11/01/06 11/22/2006 OFFICIAL RECORD COPY

Seabrook Station, Unit No. 1 cc:

Mr. J. A. Stall Ms. Cristine McComb, Director Senior Vice President, Nuclear and ATTN: John Giarrusso Chief Nuclear Officer Massachusetts Emergency Management Agency Florida Power & Light Company 400 Worcester Road P.O. Box 14000 Framingham, MA 01702-5399 Juno Beach, FL 33408-0420 Ms. Kelly Ayotte, Attorney General Mr. Peter Brann Mr. Orvil Fitch, Deputy Attorney General Assistant Attorney General 33 Capitol Street State House, Station #6 Concord, NH 03301 Augusta, ME 04333 Mr. Christopher M. Pope, Director Resident Inspector Homeland Security & Emergency Mgmt.

U.S. Nuclear Regulatory Commission New Hampshire Department of Safety Seabrook Nuclear Power Station Bureau of Emergency Management P.O. Box 1149 33 Hazen Drive Seabrook, NH 03874 Concord, NH 03301 Town of Exeter Mr. M. S. Ross, Managing Attorney 10 Front Street Florida Power & Light Company Exeter, NH 03823 P.O. Box 14000 Juno Beach, FL 33408-0420 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. Rajiv S. Kundalkar 475 Allendale Road Vice President - Nuclear Engineering King of Prussia, PA 19406 Florida Power & Light Company P.O. Box 14000 Office of the Attorney General Juno Beach, FL 33408-0420 One Ashburton Place, 20th Floor Boston, MA 02108 James M. Peschel Regulatory Programs Manager Board of Selectmen FPL Energy Seabrook, LLC Town of Amesbury PO Box 300 Town Hall Seabrook, NH 03874 Amesbury, MA 01913 Ms. Marjan Mashhadi Mr. Robert Poole Senior Attorney Federal Emergency Management Agency Florida Power & Light Company Region I 801 Pennsylvania Ave., NW Suite 220 J.W. McCormack P.O. & Washington, DC 20004 Courthouse Building, Room 401 Boston, MA 02109 Mr. Mark E. Warner Vice President, Nuclear Operations Support Mr. Tom Crimmins Florida Power & Light Company Polestar Applied Technology P.O. Box 14000 One First Street, Suite 4 Juno Beach, FL 33408-0420 Los Altos, CA 94019

REQUEST FOR ADDITIONAL INFORMATION MISCELLANEOUS TECHNICAL SPECIFICATION CHANGES FPL ENERGY SEABROOK, LLC SEABROOK STATION, UNIT NO. 1 DOCKET NO. 50-443 By letter dated August 7, 2006, FPL Energy Seabrook, LLC (FPLE) submitted license amendment request (LAR) 06-03. The LAR requested to revise various sections of the Seabrook Station, Unit No. 1 (Seabrook) Technical Specifications (TSs). This letter relates specifically to the changes proposed for TS 3.3.9, Remote Shutdown System, and TS 3.7.4, Service Water System/Ultimate Heat Sink. The Nuclear Regulatory Commission (NRC) staff has been reviewing the submittal and has determined that the following additional information is needed to complete its review with respect to the aforementioned TS sections:

1. TS Table 3.3-9 lists components requiring operable remote safe shutdown controls.

The table currently includes the turbine driven emergency feedwater (TDEFW) pump steam supply valves MS-V-127 and MS-V-128. These valves were also relied upon for addressing Title 10 of the Code of Federal Regulations (CFR 50), Appendix A, General Design Criteria (GDC) 57. FPLE stated that a design change was implemented in 1991 to replace the pneumatic actuators on these valves with gear operated manual actuators. The design change also upgraded the downstream branch header remote/manual isolation valves MS-V-393 and MS-V-394 for use as the containment isolation valves.

a. Among other things, GDC 57 states that the containment isolation valve be located as close to the containment as practical, and valves MS-V-393 and MS-V-394 are located downstream of valves MS-V-127 and MS-V-128. Please elaborate on the 1991 plant design changes that were made and justify how they continue to address this particular provision of GDC 57.

b. Explain what impact the 1991 plant design change has on the capability to mitigate a high energy line break of the TDEFW pump steam supply line, taking into consideration single active failure considerations.

2. Seabrook TS 3.7.4 specifies the actions that are required for an inoperable service water system/ultimate heat sink. Action e. requires the portable tower makeup pump system to be restored to its required condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the system is not stored in its operational readiness state. Action e. also contains a requirement to notify the NRC within one hour in accordance with 10 CFR 50.72 if the portable tower makeup pump system is not restored to its design operational readiness state within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The LAR proposes to eliminate the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reporting requirement because the condition does not meet the immediate reporting requirements of 10 CFR 50.72; and the LAR also proposes a requirement to implement actions, within the next 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, that ensure

an adequate supply of makeup water for the service water cooling tower for a minimum of 30 days.

TS 3.7.4 for Seabrook differs from the Standard Technical Specification (STS) in that it allows continued plant operation when the UHS is inoperable due to insufficient water inventory; whereas the STS requires that the plant enter a shutdown action requirement.

Because the cooling tower basin for Seabrook is not large enough to store 30 days worth of cooling water, the NRC staff allowed the makeup capability of a portable cooling tower makeup pump system to be credited. However, means other than the portable cooling tower makeup pump system for ensuring the required 30 day cooling water inventory for Seabrook have not been approved by the NRC. Therefore, if the portable cooling tower makeup pump system should become inoperable for more than the allowed outage time, prompt NRC notification and oversight would be necessary to assure that: (a) the situation is being adequately resolved, and (b) alternate means that are credited in the interim for ensuring cooling tower makeup capability are acceptable to the NRC staff.

Although the current 1-hour reporting requirements specified by 10 CFR 50.72 may no longer be applicable to the condition referred to in TS 3.7.4, the considerations discussed above continue to be valid. Therefore, to justify that the proposed changes are still considered to be appropriate, please address the considerations referred to above.