SBK-L-10143, Response to Request for Additional Information Regarding License Amendment Request (LAR) 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System

Response to Request for Additional Information Regarding License Amendment Request (LAR) 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System

ML102380100
Person / Time
Site:	Seabrook
Issue date:	08/24/2010
From:	Freeman P Nextera Energy, NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-10143
Download: ML102380100 (24)

Text

NEXTeraM ENERGY Y_

~SEABROOK August 24, 2010 10 CFR 50.90 SBK-L-10143 Docket No. 50-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Response to Request for Additional Information Regarding License Amendment Request (LAR) 10-02, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System"

References:

1. NextEra Energy Seabrook, LLC letter SBK-L-10074, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System," May 14, 2010.

2. NRC Electronic Transmission, Draft Request for Additional Information Regarding License Amendment Request Related to Containment Emergency Air Cleanup System (TAC No.

ME3988), August 5, 2010.

In Reference 1, NextEra Energy Seabrook, LLC (NextEra) submitted a request for an amendment to the Technical Specifications (TS) for Seabrook Station. The proposed amendment would add a requirement that if both trains of the containment enclosure emergency air cleanup system are inoperable, at least one train must be returned to service within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or a plant shutdown is required.

In Reference 2, the NRC requested additional information in order to complete its review of the LAR. The Enclosure to this letter contains NextEra's response to the request for additional information.

NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

United States Nuclear Regulatory Commission SBK-L-10143 / Page 2 to the enclosure provides NextEra's revised evaluation of the proposed change.

Revised markups of the TS and TS Bases are included in Attachments 2 and 3, respectively. The commitment originally provided as Attachment 4 in Reference 1 is eliminated.

The modification to the proposed change does not alter the conclusion in Reference 1 that the proposed change does not involve a significant hazard consideration pursuant to 10 CFR 50.92.

A copy of this letter has been forwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91(b).

Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.

Sincerely, NextEra Energy Seabrook, LLC.

Paul F/eemanP Site Vice President Enclosure cc:

NRC Region I Administrator G. E. Miller, NRC Project Manager, Project Directorate 1-2 W. J. Raymond, NRC Senior Resident Inspector Mr. Christopher M. Pope, Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NiH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

F:PL Seabrook Station AFFIDAVIT I, Edward Metcalf, Plant General Manager of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within this response to request for additional information regarding License Amendment Request 10-02 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 4*5' day of iIPais

,2010 Notary Public Edward Metcn a

Plant General Aanb r

Enclosure Response to Request for Additional Information (RAI)

RAIl:

The application cites TSTF-287-A as a supporting basis for allowing intermittent opening of the containment enclosure under administrative control. The NRC staff does not concur that TSTF-287-A is applicable to opening of boundaries such as the containment enclosure. Provide an independent justification for addition of this note in the Seabrook TSs.

Response to RAI 1:

NextEra has revised the license amendment request to remove the reference to TSTF-287-A as the basis for the proposed change.

RAI 2

Page 5 of Attachment 1, Paragraph 1 states that for entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. Please provide the actual actions these persons will be taking as part of the administrative control while passing through the doors. Include a discussion of the method of informing the control room operators that the containment was or will be intermittently opened and confirming it was rapidly and appropriately closed.

Response to RAI 2:

A station procedure provides directions for the actions personnel must take when passing through doors inside the protected area of the plant. These actions include:

" Ensuring the door is closed and latched following transit,

• Immediately notifying the control room and initiating a work order if a door cannot be closed or latched, Opening containment enclosure boundary doors to permit movement of people and equipment through the doorways. Propping open a containment enclosure boundary door and obstructing the doorway such that it cannot be immediately closed is not permitted.

Personnel do not notify the control room for routine transit through containment enclosure boundary doors unless they discover a deficiency, such as a failure of the door to close or latch.

An open containment enclosure boundary door initiates an alarm in Security, and

procedures require security personnel to notify the control room upon receipt of a door alarm.

RAI 3

Page 5 of Attachment 1, Paragraph 1 discusses stationed individuals for monitoring openings other than doors. Please indicate whether a dedicated individual will be stationed at each opening or if a single individual will be assigned to monitor multiple openings.

Response to RAI 3:

The license amendment request is revised to eliminate the provision that allows openings other than containment enclosure boundary doors for normal transit.

RAI 4

Justify that the administrative control of openings in the containment enclosure building will not impact the results of any dose analyses that assume a leak-tight containment enclosure with respect to both offsite and control room dose.

Response to RAI 4:

The proposed change is modified to limit the administrative control of openings to containment enclosure boundary doors for normal transit. The normal time allowed for passage of personnel and equipment through a containment enclosure boundary doorway is five minutes or less. Five minutes is considered an acceptable time for normal transit because the containment enclosure boundary doors, which will not be blocked open, can be closed quickly without special provisions. Further, the probability of a design basis accident occurring during the five-minute period is low.

NextEra Energy Seabrook's Evaluation of the Proposed Change

Subject:

License Amendment Request 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusion

6.0 REFERENCES

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1.0

SUMMARY

DESCRIPTION This license amendment request (LAR) proposes a change to Seabrook Station Technical Specification (TS) 3.6.5.1, Containment Enclosure Emergency Air Cleanup System (CEEACS). TS 3.6.5.1 does not address the condition in which both trains of the CEEACS become inoperable due to a degraded ventilation system boundary. As a result, a loss of integrity of the CEEACS ventilation area boundary requires entry into TS 3.0.3 (an orderly shutdown of the unit) for two inoperable trains of CEEACS. The proposed change would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore integrity of the ventilation area boundary before requiring shutdown of the plant. The change would also allow opening of the CEEACS ventilation area boundary doors under administrative controls.

The proposed change would resolve a discrepancy in required actions between TS 3.6.5.1 for the CEEACS, and TS 3.6.5.2, Containment Enclosure Building Integrity. Currently, TS 3.6.5.2 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore containment enclosure building integrity. However, the same condition would require entry into TS 3.0.3 for two inoperable trains of CEEACS due to an inoperable ventilation area boundary. This change would add a new action to TS 3.6.5.1, which would provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the containment enclosure boundary to operable status when two trains of CEEACS are inoperable due to an inoperable containment enclosure boundary.

2.0 DETAILED DESCRIPTION Proposed Changes:

The Limiting Condition for Operation (LCO) for TS 3.6.5.1 is modified with the following note:

The containment enclosure boundary doors may be opened for normal transit under administrative control.

The action below is added to TS 3.6.5.1:

b. With both Containment Enclosure Emergency Air Cleanup System trains inoperable due to an inoperable containment enclosure boundary, restore the boundary to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

One editorial change is made to TS 3.6.5.1. The term train is added to the LCO and action.

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The footnote that allowed a one time, seven-day extension to the allowed outage time in June 2006 is deleted.

Condition the Proposed Change is Intended to Resolve TS 3.6.5.1 requires two operable trains of CEEACS in Modes 1 through 4. Various surveillance requirements (SR) associated with this TS confirm operability of the ventilation equipment, including tests of the exhaust fans, charcoal adsorbers, HEPA filters, and system flow rates. The TS also includes a SR that verifies the CEEACS is capable of establishing a negative pressure in the containment enclosure within four minutes following a start signal. The primary purpose of this SR is to demonstrate integrity of the containment enclosure. To meet this SR, the containment enclosure boundary must be intact. If the boundary is not intact, the SR cannot be met (even if the other SRs on the ventilation equipment are met), both trains of the CEEACS cannot perform their intended function, and TS 3.0.3, which requires an orderly plant shutdown, must be entered for two inoperable trains of CEEACS.

In addition to TS 3.6.5.1, the Seabrook TS also contain two separate LCOs that require containment enclosure integrity: TS 3.6.5.2, Containment Enclosure Building Integrity; and TS 3.6.5.3, Containment Enclosure Building Structural Integrity. In the event of a failure to meet the LCO, each of these TS provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore containment enclosure integrity before a plant shutdown is required.

The proposed change would resolve the discrepancy in required actions between TS 3.6.5.1 for the CEEACS, and TS 3.6.5.2 and 3.6.5.3 for containment enclosure integrity.

The change would add a new action to TS 3.6.5.1, which would provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the containment enclosure boundary to operable status when two trains of CEEACS are inoperable due to an inoperable containment enclosure boundary.

=

Background===

Description of the Containment Enclosure Building The containment enclosure building is located outside the containment The function of the containment enclosure is to collect any fission products which could leak from the primary containment structure into the containment enclosure and contiguous areas (electrical penetration areas, mechanical piping penetration area, and engineered safeguard equipment cubicles) following a loss-of-coolant accident (LOCA). The containment enclosure provides a low leakage rate barrier between these areas and the environment to control all leakage from the primary containment boundary. The system is comprised of (a) a structural barrier surrounding the containment, adjacent vaults and 3

penetration areas; and (b) a CEEACS, which maintains a pressure lower than ambient in the enclosure to prevent uncontrolled releases of radioactivity into the environment. The presence of the containment enclosure and the use of the CEEACS produce a slightly negative pressure between the containment enclosure and its external surroundings to minimize direct leakage from the containment structure to the environment under accident conditions. One train of CEEACS is required to draw down the entire containment enclosure area to a negative differential pressure within 8 minutes following a LOCA.

Current Technical Specifications Associated with the Containment Enclosure Building

• TS 3.6.5.1, Containment Enclosure Emergency Air Cleanup System, requires two operable trains of the CEEACS in Modes 1 through 4. With one train of CEEACS inoperable, the TS provides 7 days to restore the inoperable train to operable status.

TS 3.6.5.2, Containment Enclosure Building Integrity, requires containment enclosure building integrity in Modes 1 through 4. Without integrity, the TS provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore integrity.

TS 3.6.5.3, Containment Enclosure Building Structural Integrity requires containment enclosure building structural integrity in Modes 1 through 4.

Upon a failure to meet the LCO, the TS provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore structural integrity.

Proposed Changes The proposed change addresses the condition in which both trains of the CEEACS are rendered inoperable due to an inoperable containment enclosure boundary. While TS 3.6.5.2 and 3.6.5.3 provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore containment enclosure building integrity and containment enclosure structural integrity, TS 3.6.5.1 does not address degraded or inoperable containment enclosure integrity.

SR 4.6.5.l.d.4 verifies that each train of the CEEACS is capable of producing a negative pressure in the containment enclosure. While other SRs in the same specification test operability of the ventilation equipment, the primary purpose of the negative pressure test is to demonstrate integrity of the containment enclosure building. However, TS 3.6.5.1 does not include an action for a failure to meet the negative pressure test SR. Under the existing specifications, TS 3.0.3 must be entered for two inoperable trains of CEEACS when the negative pressure test cannot be met due to an inoperable containment enclosure boundary. Requiring the plant to enter TS 3.0.3 when the containment enclosure boundary is not intact does not provide time to effect required repairs or 4

corrective maintenance activities, and is inconsistent with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> actions provided in TS 3.6.5.2 and 3.6.5.3 to restore containment enclosure integrity.

The first proposed change modifies the LCO for TS 3.6.5.1 to state that the containment enclosure boundary doors may be opened intermittently under administrative controls.

This change is similar to the provision that currently exists in surveillance requirement 4.6.5.2 for the containment enclosure boundary doors: "CONTAINMENT ENCLOSURE BUILDING INTEGRITY shall be demonstrated at least once per 31 days by verifying that the door in each access opening is closed except when the access opening is being used for normal transit entry and exit." For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. The normal time allowed for passage of personnel and equipment through a containment enclosure boundary doorway is five minutes or less. Five minutes is considered an acceptable time for normal transit because the containment enclosure boundary doors, which will not be blocked open, can be closed quickly without special provisions. Further, the probability of a design basis accident occurring during the five-minute period is low.

The second proposed change adds a new action requirement to TS 3.6.5.1 for two trains of CEEACS rendered inoperable due to an inoperable containment enclosure boundary.

Currently, if one CEEACS train is determined to be inoperable, the existing action requirement would apply and require restoring the train to operable status within 7 days.

However, if two trains are determined to be inoperable due to an inoperable containment enclosure boundary, immediate entry into the shutdown actions of TS 3.0.3 is required.

Although TS 3.6.5.2 and 3.6.5.3 allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore containment enclosure building integrity before requiring a plant shutdown, TS 3.6.5.1 does not address the same condition by providing time to restore the boundary before requiring a plant shutdown.

TS 3.6.5.2, Containment Building Enclosure Integrity, and TS 3.6.5.3, Containment Enclosure Building Structural Integrity, both require containment enclosure integrity in modes 1 through 4. Without integrity, the containment enclosure may not limit direct leakage from the containment to the environment under accident conditions. As a result, each TS allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore integrity if the LCO is not met. The 24-hour allowance is consistent with the bases for TS 3.6.8, Shield Building, in NUREG-1431, Standard Technical Specifications Westinghouse Plants [Reference 1], which discusses that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable completion time to restore an inoperable shield building considering the limited leakage design of containment and the low probability of a design basis accident occurring during this time period. (The TS limitations on the shield building, which include continuously maintaining the building under a negative pressure and preventing any breach of the shield building, are more restrictive than the requirements for the containment enclosure.) The proposed 24-hour completion time would have no impact on core damage frequency or large early release frequency. The CEEACS does not mitigate core damage and the Seabrook Probabilistic Risk Analysis assumes that a breach of containment overwhelms the filtration capacity of the CEEACS.

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An opening in the containment enclosure boundary would not prevent the CEEACS from starting and initiating flow through the cleanup system on an actuation signal. However, the system may not be capable of establishing the required negative pressure within the required time or in all contiguous areas of the containment enclosure. The consequences of both trains of the CEEACS becoming inoperable due to an inoperable containment enclosure boundary are the same as the consequences of a failure to meet the LCO of TS 3.6.5.2 or TS 3.6.5.3, which require containment enclosure integrity. Therefore, the basis for the 24-hour completion time in the proposed action is the same as the basis for the time permitted to restore containment enclosure integrity. Twenty four hours is a reasonable completion time to restore containment enclosure building integrity when both trains of the CEEACS are inoperable due to an inoperable containment enclosure boundary considering the limited leakage design of primary containment and the low probability of a design basis accident occurring during this time period. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period is also a reasonable time to diagnose, plan, repair, and test most problems with the containment enclosure boundary.

One editorial change is included in this proposed change. The term train is added to the LCO and action in TS 3.6.5.1. The current TS discusses two Containment Enclosure Emergency Air Cleanup Systems. The TS is revised to refer to two trains of the emergency air cleanup system rather than two systems. This change makes TS 3.6.5.1 consistent with the other TS for emergency ventilation systems. This change improves the quality and presentation of the TS, is editorial in nature, and has no impact on safety.

In addition, the footnote that allowed a one time, seven-day extension to the allowed outage of TS 3.6.5.1 in June 2006 is deleted. This is a non-substantive administrative change that removes from the TS a provision that is no longer applicable.

Precedent The proposed changes are similar to provisions that exist in the TS in NUREG-1431 for certain emergency air cleanup systems. The CEEACS is designed to maintain a negative pressure of greater than or equal to 0.25 inches of water, following a design basis accident, in the annular region defined by the containment structure and the containment enclosure, as well as in the additional building volumes associated with the electrical penetration areas, mechanical piping penetration area and engineered safeguard equipment cubicles, so that any fission products leaking from these systems and from the primary containment will be retained in these areas and eventually processed through the filters The system is designed to limit offsite post-accident doses to values below those specified in 10 CFR 100.

The function of the CEEACS to maintain a negative pressure in the engineered safeguard equipment cubicles is similar to the function performed by the Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS) included in TS 3.7.12 in NUREG-1431. Similar to the CEEACS, the design basis of the ECCS PREACS 6

is to limit the radioactive release to within the limits of 10 CFR 100 in the event of a failure of the ECCS outside containment. Surveillance requirement (SR) 3.7.12.4 verifies integrity of the ECCS pump room enclosure by verifying the ability of the PREACS to maintain a negative pressure in the pump room. With two ECCS PREACS trains inoperable due to an inoperable ECCS pump room boundary, TS 3.7.12, Condition B provides a 24-hour completion time to restore the boundary to operable status. The change proposed by this amendment request is similar to Condition B in TS 3.7.12.

The CEEACS also provides the design function performed by the Penetration Room Exhaust Air Cleanup System, which is addressed in TS 3.7.14 in NUREG-1431. The PREACS filters air from the penetration area to restrict the radioactive release to within the limits of 10 CFR 100 in the event of a failure, such as valve packingjeakage, outside containment. This TS also includes a surveillance requirement that demonstrates integrity of the penetration room by verifying the ability of the PREACS to maintain a negative pressure in the penetration room. With two PREACS trains inoperable due to an inoperable penetration room boundary, TS 3.7.14, Condition B provides a 24-hour completion time to restore the boundary to operable status. The change proposed by this amendment request is similar to Condition B in TS 3.7.14.

Conclusion The proposed change would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore an inoperable containment enclosure boundary before requiring the unit to shutdown due to two inoperable trains of CEEACS and also allow intermittent opening of the containment enclosure boundary doors under administrative controls. Based on the low probability of an event occurring during the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the containment enclosure boundary is not intact, NextEra concludes that this change is acceptable.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, Technical Specifications - requires that the TS include limiting conditions for operation, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

10 CFR 50.67, Accident Source Term - establishes limits on the accident source term used in design basis radiological consequence analyses with regard to radiation exposure to members of the public and to control room occupants.

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General Design Criterion 16, Containment design - 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.

General Design Criterion 19--Control room - A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.

General Design Criterion 60 - Control of releases of radioactive materials to the environment - The nuclear power unit design shall include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid wastes produced during normal reactor operation, including anticipated operational occurrences.

General Design Criterion 64--Monitoring radioactivity release - Means shall be provided for monitoring the reactor containment atmosphere, spaces containing components for recirculation of loss-of-coolant accident fluids, effluent discharge paths, and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences, and from postulated accidents.

Conclusion The containment enclosure building integrity ensures that the release of radioactive materials from the primary containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses.

This restriction, in conjunction with operation of the CEEACS limits the site boundary radiation doses to within the dose guideline values of 10 CFR 50.67 during accident conditions. The proposed changes do not impact the ability of an operable CEEACS to perform its intended function. In the case that the containment enclosure boundary is inoperable, the proposed new action requirement imposes a 24-hour time limit to restore the inoperable boundary.

Based on the low probability of an accident occurring during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period that the CREACS trains are inoperable, NextEra concludes the proposed change is acceptable and complies with applicable regulatory requirements.

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4.2 Significant Hazards Consideration No Significant Hazards Consideration In. accordance with 10 CFR 50.92, NextEra Energy Seabrook has concluded that the proposed change does not involve a significant hazards consideration (SHC).

The basis for the conclusion that the proposed changes do not involve a SHC is as follows:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change does not impact the physical function of plant structures, systems, or components (SSCs) or the manner in which SSCs perform their design function. The proposed changes neither adversely affect accident initiators or precursors, nor alter design assumptions. The proposed changes do not alter or prevent the ability of operable structures, systems, and components (SSCs) to perform their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits.

This change is a revision to the technical specifications (TS) for the containment enclosure emergency air cleanup system (CEEACS), wrhich is a mitigation system designed to prevent uncontrolled releases of radioactivity into the environment. The change would allow intermittent opening of the containment enclosure boundary doors under administrative controls. These controls would ensure that the opening will be quickly sealed to maintain the validity of the licensing basis analyses of accident consequences. The proposed change adds a new action requirement that would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the containment enclosure boundary in the event that both trains of the CEEACS are inoperable due to an inoperable containment enclosure boundary. The proposed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time is reasonable based on the low probability of a design basis accident occurring during this time period.

The CEEACS is not an initiator or precursor to any accident previously evaluated. Therefore, the probability of any accident previously evaluated is not increased.

2. The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

The proposed changes will not impact the accident analysis. The changes will not alter the requirements of the CEEACS or its function during accident 9

conditions, and no new or different accidents result from the proposed changes to the TS. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a significant change in the method of plant operation. The changes do not alter assumptions made in the safety analysis. Therefore, this request does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed changes do not involve a significant reduction in the margin of safety.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public.

The proposed changes do not involve a significant change in the method of plant operation, and no accident analyses will be affected by the proposed changes. Additionally, the proposed changes will not relax any criteria used to establish safety limits, will not relax any safety system settings, and will not relax the bases for any limiting conditions for operation. The safety analysis acceptance criteria are not affected by this change. The proposed change will not result in plant operation in a configuration outside the design basis. The proposed change does not adversely affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condition.

Therefore, these proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, NextEra Energy Seabrook, LLC, concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(b), and, accordingly, a finding of"no significant hazards consideration" is justified.

4.3 Conclusions Based on the considerations discussed above, (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 Commission's 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.

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5.0 ENVIRONMENTAL CONSIDERATION

NextEra has evaluated the proposed amendment for environmental considerations. The review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set for in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 3 11 Mark-up of the Technical Specifications (TS)

Refer to the attached markup of the TS showing the proposed changes. The attached markups reflect the currently issued version of the TS and Facility Operating License.

At the time of submittal, the Facility Operating License was revised through Amendment No. 123.

Listed below are the license amendment requests that are awaiting NRC approval and may impact the currently issued version of the Facility Operating License affected by this LAR.

LAR Title NextEra Energy Date Seabrook Letter Submitted Revision to Technical Specification SBK-L-09118 05/28/2009 LAR 09-03 6.7.6.k, "Steam Generator (SG)

Program," for Permanent Alternate Repair Criteria (H*)

LAR 09-04 Amendment to the Facility SBK-L-09218 11/19/2009 Operating License and Submittal of the Seabrook Station Cyber Security Plan LAR 10-01 Operations Manager Qualification SBK-L-10010 03/16/2010 Requirements The following TS pages are included in the attached markup:

Technical Page Specification Title TS 3.6.5.1 Containment Enclosure Emergency Air Cleanup System 3/4 6-21

INSERT 1 NOTE The containment enclosure boundary doors may be opened for normal transit under administrative control INSERT 2

b. With both Containment Enclosure Emergency Air Cleanup System trains inoperable due to an inoperable containment enclosure boundary, restore the boundary to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

CONTAINMENT SYSTEMS 3/4.6.5 CONTAINMENT ENCLOSURE BUILDING CONTAINMENT ENCLOSURE EMERGENCY AIR CLEANUP SYSTEM LIMITING CONDITION FOR OPERATION 3.6.5.1 Two independent Containment Enclosure Emergency Air Cleanup System/shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

(H-)With one:Containm et Enclosure Emergency Air Clearup System inoperable, restore the inoperabl to OPERABLE status within 7 day?'7or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.5.1 Each Containment Enclosure Emergency Air Cleanup System shall be demonstrated OPERABLE:

a.

At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes;

b.

At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:

1)

Verifying that the cleanup system satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978*, and the system flow rate is 2100 cfm +/- 10%;

2)

Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, by showing a methyl iodide penetration of less than or

1. _The 7-da allowed'o age time whicwas entered o9; tfne 4, 2006 at

ao2hours, maybel Mtended one !tyeJpy an addit'jp, l 7 days to gordVIete repair and,,tsing on theeeeeJ Containmen-t'Enclosure VentiTation Area rebTrn fan EAH-FN.0-0"0B.

• ANSI N510-1980 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52, Rev. 2, March 1978.

SEABROOK - UNIT 1 3/4 6-21 Amendment No. 7-5,-

Mark-up of the Technical Specification Bases

BASES INSERT 3/4.6.5.1 CONTAINMENT ENCLOSURE EMERGENCY AIR CLEANUP SYSTEM (CEEACS)

BACKGROUND The CEEACS is designed to maintain a negative pressure of greater than or equal to 0.25 inches of water, following a design basis accident, in the annular region defined by the containment structure and the containment enclosure, as well as in the additional building volumes associated with the electrical penetration areas, mechanical piping penetration area and engineered safeguard equipment cubicles. Any fission products leaking from these systems and from the primary containment will be retained in these areas and eventually processed through the filters.

The filter system consists of redundant filter trains, fans, dampers and controls and a common ductwork system. The air flow required to maintain a negative pressure in the Containment Enclosure Building is passed through dernisters, which also function as prefilters, and through HEPA filters located both upstream and downstream of the carbon filter prior to exhausting through the plant vent. A ductwork cross-connection is provided between the two filter trains at a point between the downstream HEPA filter and the fan inlet. Should the operating fan fail, this cross-connection will insure a continued air flow by manual startup of the redundant fan. Each redundant filter train is complete, separate and independent from both electrical and control standpoints. Each filter train fan is supplied power from an independent ESF power train source.

APPLICABLE SAFETY ANALYSIS In the event of an accident requiring CEEACS operation, both of the redundant filter train fans will be automatically started on a "T" signal. One train of the Containment Enclosure Emergency Cleanup System is required to be able to draw down the entire Containment Enclosure Area to a negative differential pressure of 0.25 inches of water.

This differential pressure is required to be established between all areas that comprise the Containment Enclosure Area and their external surroundings.

Analysis has shown that one containment enclosure exhaust filter fan is capable of drawing down the entire containment enclosure area to the design negative differential pressure in less than 8 minutes after the initiation of a design basis LOCA. This analysis takes into account the engineered safety feature actuation system signal delay time, delay time for the diesel generator to supply power in the event of a simultaneous loss of offsite power, and the time for the filter fan to come up to speed.

1

LCO One train of the CEEACS is required to maintain a negative pressure within the containment enclosure following an accident, to remove and retain airborne particulates and radioactive iodine, and to exhaust filtered air to the unit plant vent. Two trains of the CEEACS must be OPERABLE to ensure that at least one train will operate, assuming that the other train is disabled by a single active failure.

The CEEACS also provides cooling to the following areas and equipment during normal and emergency operation: containment enclosure ventilation equipment area, the charging pumps, safety injection pumps, residual heat removal pumps, containment spray pumps, and the mechanical penetration area. However, the cooling function is not associated with this TS, but rather is controlled under Technical Requirement 24, Area Temperature Monitoring.

The components associated with this TS include those dampers, fans, filters, etc., and required ductwork and instrumentation that evacuate or isolate areas, route air, and filter the exhaust prior to discharge to the environment. Included among these components are:

Containment enclosure cooling fans (EAH-FN-5A and 5B)

Containment enclosure ventilation area return fans (EAH-FN-3 1 A and 31 B)

Containment enclosure emergency exhaust fans (EAH-FN-4A and 4B)

Charging pump room return air fans (EAH-FN-180A and 180B)

Containment enclosure emergency clean up filters (EAH-F-9 and F-69)

• PAB / CEVA isolation dampers (PAH-DP-35A, 36A, 35B, and 36B)

The LCO is modified by a note allowing the containment enclosure boundary doors to be opened for normal transit under administrative controls. For entry and exit through doors, administrative control of the opening is performed by the person(s) entering or exiting the area. The normal time allowed for passage of personnel and equipment through a containment enclosure boundary doorway is five minutes or less. Five minutes is considered an acceptable time for normal transit because the containment enclosure boundary doors, which will not be blocked open, can be closed quickly without special provisions. Further, the probability of a design basis accident occurring during the five-minute period is low ACTIONS a.

Action a requires that with one CEEACS train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The 7 day completion time considers the availability of the OPERABLE redundant CEEACS train and the low probability of a design basis accident occurring during this period. If the CEEACS train cannot be restored to OPERABLE status within the 7 days, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at 2

least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The completion times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant.

b.

If the containment enclosure boundary is inoperable, the CEEACS trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE containment enclosure boundary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time is reasonable based on the low probability of a design basis accident occurring during this time period. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time is a typically reasonable time to diagnose, plan, repair, and test most problems with the containment enclosure boundary.

If the containment enclosure boundary cannot be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The completion times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

3

CONTAINMENT SYSTEMS BASES 3/4.6.5 CONTAINMENT ENCLOSURE BUILDING 3/4.6.A C1ONTAINMENT ENCLOSURE EMERGENCY AIR CLEANUP SYSTEM The OPERABILITY of the Contamefit Enclosure Emergency Air Cleanup System ensures that during LOCA cond** ns containment vessel leakage into the annulus, and radioactive materials leakjng-from engineered safety features equipment, from the electrical penetration areas, andliom the mechanical penetration tunnel, will be filtered through the HEPA filtersna ridcharcoal adsorber trains prior to discharge to the atmosphere.

The EAH system components associated with this Techaieal Specification include those dampers, fans, filters, etc., and required ductwork i"instrumentation that evacuate or isolate areas, route air, and filter the exhaust prirto discharge to the environment.

Included among these components are:

0 Containment enclosure cooljngfans (EAH-FN-5A and 5B)

& Containment enclosure.veiitilation area return fans *_AH-FN-31A and 31 B)

Containment enclostire emergency exhaust fan'.('EAH-FN-4A and 4B) 0 Charging.pump room return air fans (EAH-, E-180A and 180B)

.Containment enclosure emergency cle1"up filters (EAH-F-9 and F-69)

PAB / CEVA isolation dampers (P 11-DP-35A, 36A, 35B, and 36B)

The EAH system also provide oling to the following areas aný lu'ipment during normal and emergency operation. containment enclosure ventila rroequipment area, the gpumps, safety irnetion pumps, residual heat rem(ýva pumps, containment spray /

pumps, and the mechanical penetration area. Howevy, the EAH cooling function is not associated with this Technical Specification, but.rat er is controlled under Technical i

Requirement 24, Area Temperature Monitoring.-

3/4.6.5.2 CONTAINMENT ENCLOSURE BUILDING INTEGRITY CONTAINMENT ENCLOSURE BUILDING INTEGRITY ensures that the release of radioactive materials from the primary containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses. This restriction, in conjunction with operation of the Containment Enclosure Emergency Air Cleanup System, will limit the SITE BOUNDARY radiation doses to within the dose guideline values of 10 CFR 50.67 during accident conditions.

Verifying that the enclosure boundary is intact, or has integrity, involves confirming that the doors are closed except during normal transit entry and exit. Additionally, pressure boundary seals must also be intact to maintain the integrity of the containment enclosure.

SEABROOK-UNIT 1 B 3/4 6-5 Amendment No. 49, BC 04 05 04-06, 04412, 08-02 A