ML120470586
| ML120470586 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/22/2012 |
| From: | John Lamb Plant Licensing Branch 1 |
| To: | Freeman P NextEra Energy Seabrook |
| Lamb J, NRR/DORL, 301-415-3100 | |
| References | |
| TAC ME3988 | |
| Download: ML120470586 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 22, 2012 Mr. Paul Freeman Site Vice President clo Michael O'Keefe Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874
SUBJECT:
SEABROOK STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE ADDITION OF ACTION STATEMENT TO LIMITING CONDITION FOR OPERATION 3.6.5.1, "CONTAINMENT ENCLOSURE EMERGENCY AIR CLEANUP SYSTEM" (TAC NO. ME3988)
Dear Mr. Freeman:
By letter dated May 14, 2010,1 as supplemented by letters dated August 24,2010,2 and September 16, 2011,3 NextEra Energy Seabrook, LLC (NextEra or the licensee) submitted license amendment request (LAR) LAR 10-02 to revise the technical specifications for Seabrook Station, Unit No.1 (Seabrook). The proposed amendment would add an action statement to Limiting Condition for Operation 3.6.5.1 to allow operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when both trains of the Containment Enclosure Emergency Air Cleanup System are inoperable due to an inoperable Containment Enclosure Building. Additionally, the amendment would make some minor wording changes, add a clarifying note, and remove a footnote.
The U.S. Nuclear Regulatory Commission (NRC) has determined that additional information is required to complete its review. The NRC staffs request for additional information (RAI) is contained in the enclosed RAI. A draft of these questions was previously sent to Mr. Michael O'Keefe of your staff with an opportunity to have a teleconference to ensure that the licensee understood the questions and their regulatory basis, as well as to verify that the information was not previously docketed. A conference call was held on February 21,2012, and Mr. O'Keefe agreed that NextEra Energy Seabrook, LLC would respond to the RAI within 30 days of the date of this letter. Please note that if you do not respond to the RAI within 30 days, the NRC staff may reject your request for relief under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108, "Denial of application for failure to supply information."
1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML101390041 2 ADAMS Accession No. ML102380100 3 ADAMS Accession No. ML11266A041
P. Freeman
- 2 If you have questions, you can contact me at 301-415-3100 and/or John.Lamb@nrc.gov.
Si"[r~$~
JO~b' Senior Project Manager PY~mt Licensing Branch 1-2
!:1iVision of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION THE ADDITION OF ACTION STATEMENT TO LIMITING CONDITION FOR OPERATION 3.6.5.1, "CONTAINMENT ENCLOSURE EMERGENCY AIR CLEANUP SYSTEM" NEXTERA ENERGY SEABROOK, LLC SEABROOK STATION, UNIT 1 DOCKET NUMBER 50-443 1.0 SCOPE By letter dated May 14, 2010,1 as supplemented by letters dated August 24,2010,2 and September 16, 2011,3 NextEra Energy Seabrook, LLC (NextEra or the licensee) submitted license amendment request (LAR) 10-02 to revise the technical specifications (TSs) for Seabrook Station, Unit No. 1 (Seabrook). The proposed amendment would add an action statement to Limiting Condition for Operation (LCO) 3.6.5.1 to allow operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when both trains of the Containment Enclosure Emergency Air Cleanup System (CEEACS) are inoperable due to an inoperable Containment Enclosure Building (CEB). Additionally, the amendment would make some minor wording changes, add a clarifying note, and remove a footnote.
The U.S. Nuclear Regulatory Commission (NRC) has determined that additional information is required to complete its review. The NRC staff's request for additional information (RAI) is contained below.
2.0 REQUEST FOR ADDITIONAL INFORMATION Question 1 By letter dated September 16, 2011, NextEra Energy Seabrook (Seabrook), LLC (licensee) submitted "Response to Request for Additional Information Regarding License Amendment Request 10-02, Regarding the Containment Enclosure Emergency Air Cleanup System." The NRC staff request for additional information stated:
Given the differences in format and content between NUREG-1431 and Seabrook TS, please describe how the proposed TS change provides an equivalent level of safety compared to that found in NUREG-1431.
The NRC staff received a response to its request that compared the Seabrook containment design function to the containment design function in NUREG-1431, Standard Technical Specifications Westinghouse Plants (STS). The response concluded that the Seabrook's 1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML101390041 2 ADAMS Accession No. ML102380100 3 ADAMS Accession No. ML11266A041 Enclosure
- 2 Containment Enclosure Building Integrity (TS 3.6.5.3) is similar to the STS Shield Building (TS 3.6.8) in that the Enclosure Building forms a secondary boundary to containment. The difference between the design functions is that Seabrook's Containment Enclosure Building is maintained at a negative pressure following an accident (emphasis added), not prior to the event as is assumed for the STS design function. Consequently, the Seabrook Containment Enclosure Building Integrity TS 3.6.5.2 permits breaching the boundary in Surveillance Requirement (SR) 3.6.5.2 during "normal transit entry and exit" through the single door access openings.
The licensee response also compared the Seabrook TS proposed required actions for an inoperable Containment Enclosure Building to STS required actions for an inoperable Shield Building. The comparison discussed that Shield Building TS 3.6.8 requires SR 3.6.8.4 to be performed and met to demonstrate Shield Building operability. SR 3.6.8.4 verifies that the Shield Building can be maintained at a specified negative pressure with a specified air flow within a specified time following receipt of actuation signal by the Shield Building Air Cleanup System (TS 3.6.13). The licensee concluded that the primary purpose of the STS SR 3.6.8.4 is to ensure Shield Building integrity (emphasis added), i.e., operability. Compared to the STS, the Seabrook Containment Enclosure Emergency Air Cleanup System (CEEACS) SR 4.6.5.1.d.4 demonstrates the CEEACS (TS 3.6.5.1) is operable by verifying the CEEACS system produces a negative pressure of greater than or equal to 0.25 inch water gauge in the annulus within 4 minutes after a start signal. The licensee concluded that the primary purpose of proposed required Action b for CEEACS is to allow a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time for both air-handling trains inoperable due to an inoperable boundary (emphasis added). For Seabrook, only the Containment Enclosure Building operability is affected when doors are opened, except for normal transit entry and exit. Thus, boundary integrity allowed outage time allowances are addressed differently in STS, as compared to proposed Seabrook TS required actions.
Seabrook TS definition 1.21, "Operable/Operability" requires:
A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s), and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing their related support function(s).
In accordance with the regulations under 10 CFR 50.36{c)(2{i), "Limiting conditions for operation 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." Also under 10 CFR 50.36(c)(3), "Surveillance requirements are requirements relating to test [...] to assure that the necessary quality of systems and components is maintained, [... ] and that the limiting conditions for operation will be met."
Based on the RAI response, the NRC staff considered that Seabrook CEEACS, Shield Building and Structural Integrity TS surveillances do not matchup with STS Shield Building Air Cleanup System (SBACS) and Shield Building surveillances. For Seabrook, only the Containment
- 3 Enclosure Building operability is affected when doors are opened, except for normal transit entry and exit. Specifically, STS Shield Building SR 3.6.8.4 demonstrates that the Shield Building is operable by verifying that the SBACS (TS 3.6.13) will maintain the Shield Building at a pressure equal to or more negative than [-0.5] inch water gauge in the annulus with final flow::;; [ ] cfm within [22] seconds after a start signal. Contrary to STS, Seabrook CEEACS SR 4.6.5.1.d.4 demonstrates the CEEACS is operable by verifying the CEEACS system produces a negative pressure of greater than or equal to 0.25 inch water gauge in the annulus within 4 minutes after a start signal. Thus, boundary integrity allowed outage time allowances are addressed differently in STS as compared to proposed Seabrook TS required actions.
Please provide additional justification for why Seabrook SR 4.6.5.1.d.4 demonstrates operability of the Seabrook CEEACS or propose other TS changes such that this negative pressure test is associated with demonstrating operability of the Containment Enclosure Building Integrity (LCO 3.6.5.2).
Question 2 The licensee's September 16, 2011, response to the NRC staff's RAI compared the Seabrook containment to the containment arrangements addressed in NUREG-1431. The discussion concluded that Seabrook's Containment Enclosure Building is similar to the Shield Building described in NUREG-1431.
The Shield Building functions to ensure proper operation of the SBACS and to limit radioactive leakage from the containment to those paths and leakage rates assumed in the accident analysis. SBACS functions to ensure that radioactive materials that leak from the Primary containment into the Shield Building following a design-basis accident are filtered and absorbed prior to exhausting to the environment. NUREG-1431, STSs 3.6.8 and 3.6.13 provide the specific requirements for the Shield Building and SBACS, respectively, to ensure they meet the intended functions.
In establishing the Shield Building requirements, the staff describes in the Bases of STS 3.6.8 that the intent is to not breach the Shield Building boundary at any time when the Shield Building is required. The staff indicates this is achieved by maintaining the barrier closed at all times. The staff also describes that Shield Building access doors are normally kept closed, except when the access opening is being used for entry and exit or when maintenance is being performed on an access opening. In establishing the SBACS requirements, the staff describes in the Bases of STS 3.6.13 that in the event of a design-baSiS accident, one SBACS train is required to provide the minimum particulate iodine removal assumed in the safety analysis.
The proposed change attempts to model the TS requirements for the Seabrook Containment Enclosure Building and the CEEACS to be consistent with NUREG-1431 requirements for the Shield Building and SBACS. The proposed changes include the insertion of a note to Seabrook TS 3.6.5.1 which states: "[t]he containment enclosure boundary doors may be opened for normal transit under administrative controL" Based on the background provided above, please provide a justification for the proposed note to provide assurance consistent with STSs 3.6.8 and 3.6.13 that radioactive leakage from the containment will be limited to those paths and leakage rates assumed in the accident analysis.
P. Freeman
- 2 If you have questions, you can contact me at 301-415-3100 and/or John.Lamb@nrc.gov.
Sincerely, Ira!
John G. Lamb, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443
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