ML14276A431

Request for Additional Information Regarding License Amendment 14-03, Changes to Technical Specification 3.3.3.1, Radiation Monitoring for Plant Operations

ML14276A431
Person / Time
Site:	Seabrook
Issue date:	10/30/2014
From:	John Lamb Plant Licensing Branch 1
To:	Dean Curtland, Ossing M NextEra Energy Seabrook
Lamb J
References
TAC MF4572
Download: ML14276A431 (7)

Text

October 30, 2014 Mr. Dean Curtland, Site Vice President c/o Michael Ossing Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT 14-03, CHANGES TO TECHNICAL SPECIFICATION 3.3.3.1, RADIATION MONITORING FOR PLANT OPERATIONS (TAC NO. MF4572)

Dear Mr. Curtland:

By letter dated July 24, 2014 (Agencywide Documents Access and Management System Accession No. ML14209A919), NextEra Energy Seabrook, LLC (NextEra or the licensee) requested a license amendment request (LAR) to change the Technical Specifications (TSs) for Seabrook Station, Unit 1 (Seabrook). The proposed LAR would modify TS 3.3.3.1, Radiation Monitoring for Plant Operations.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required to complete its review. The NRC staff's request for additional information (RAI) is contained in the enclosure.

A draft of these questions was previously sent to Mr. Mike Ossing of your staff on October 1, 2014, with an opportunity to have a teleconference to ensure that NextEra 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 October 23, 2014, and Mr. Kilby of your staff agreed that NextEra would respond to the RAI by December 12, 2014. Please note that if you do not respond to the RAI by the agreed upon date, the NRC staff may reject your amendment under the provisions of 10 CFR, Section 2.108, Denial of application for failure to supply information.

D. Curtland If you have any questions, please contact me at (301) 415-3100.

Sincerely,

/RA/

John G. Lamb, Senior 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: Distribution via Listserv

ML14276A431

• via e-mail **via memo OFFICE LPL1-2/PM LPL1-2/LA* ARCB/BC** SCVB/BC** LPL1-2/BC LPL1-2/PM NKaripineni NAME JLamb ABaxter UShoop MKhanna JLamb for RDennig DATE 10/15/14 10/14/14 10/01/14 10/14/14 10/30/14 10/30/14 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST 14-03 CHANGES TO TECHNICAL SPECIFICATION 3.3.3.1, RADIATION MONITORING FOR PLANT OPERATIONS NEXTERA ENERGY SEABROOK, LLC SEABROOK STATION, UNIT 1 DOCKET NUMBER 50-443 1.0 SCOPE By letter dated July 24, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14209A919), NextEra Energy Seabrook, LLC (NextEra or the licensee) requested a license amendment request (LAR) to change the Technical Specifications (TSs) for Seabrook Station, Unit 1 (Seabrook). The proposed LAR would modify TS 3.3.3.1, Radiation Monitoring for Plant Operations.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required to complete its review.

2.0 REQUEST FOR ADDITIONAL INFORMATION ARCB-RAI-1 In a letter dated November 7, 2013 (ADAMS Accession No. ML13246A358), the NRC staff informed the Technical Specifications Task Force (TSTF) of concerns that the NRC staff had recently identified during a review of plant-specific license amendments requesting adoption of three travelers including traveler TSTF-51, Revision 2, Revise Containment Requirements during Handling Irradiated Fuel and Core Alterations (ADAMS Accession No. ML040400343).

In a letter dated July 24, 2014, page 9 of the LAR states that the proposed change is consistent with TSTF-51-A.

TSTF-51 states, in part, that:

The addition of the term recently associated with handling irradiated fuel in all of the containment function Technical Specification requirements is only applicable to those licensees who have demonstrated by analysis [emphasis added] that after sufficient radioactive decay has occurred, off-site doses resulting from a fuel handling accident remain below the Standard Review Plan limits (well within 10 CFR 100) [or 10 CFR 50.67].

Enclosure

NUREG-0800, Standard Review Plan (SRP) 15.0.1, Radiological Consequence Analyses Using Alternative Source Terms, dated July 2000 (ADAMS Accession Number ML003734190),

states, in part, that:

The models, assumptions, and parameter inputs used by the licensee should be reviewed to ensure that the conservative design basis assumptions outlined in RG-1.183 have been incorporated.

Appendix B of Regulatory Guide (RG) 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors (ADAMS Accession Number ML003716792), Regulatory Position 1.1 states, in part, that:

The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case.

After reviewing the information submitted by NextEra that is consistent with TSTF-51, the NRC staff would like to review an analysis that shows that the fuel handling accident (FHA) doses remain within regulatory limits (when references to Core Alterations and irradiated fuel are removed from the TSs). The analysis cited on page 9 of the LAR (Amendment No. 94, dated October 3, 2003, ADAMS Accession Number ML032740512) does not appear to consider an inoperable Manipulator Crane Area Monitor with movement of loads other than irradiated fuel assemblies (such as sources, new fuel, tools or reactivity components).

a. For the proposed change, please provide an FHA analysis that evaluates the dropping of loads allowed over irradiated fuel assemblies (i.e., sources, new fuel or reactivity control components) onto irradiated fuel assemblies with an inoperable Manipulator Crane Area Monitor. The analysis should only credit those safety systems required to be operable as required by TS. Provide the inputs, assumptions and methodology used, and the results. Provide a justification for any assumptions made. Although it is not required, the NRC staff has found it more efficient if the licensees calculation is provided.

b. The LAR cites Amendment No. 94 as a justification for the proposed LAR, but Amendment No. 94 does not appear to support the current licensing basis. In Amendment No. 100, dated February 24, 2005 (ADAMS Accession Number ML050320373), a revised FHA was approved. At the time the revised FHA was approved, it appears that TS 3.3.3.1 required instrumentation that initiates containment ventilation isolation. Without the isolation of the containment purge system operable, radioactivity from the FHA could be released from the containment purge and exhaust system. Amendment No. 100 assumes the containment personnel hatch is the release pathway. Justify why releases from the containment and purge exhaust system (with an inoperable containment purge system) result in FHA doses that are lower than those from the containment personnel hatch.

ARCB-RAI-2 TS 3.3.3.1 requires two operable channels of the containment post-Loss-of-Coolant Accident (LOCA) area radiation monitor in Modes 1 through 6. On the other hand, TS 3.3.3.6, Accident Monitoring Instrumentation (AMI), only requires operability of the monitor in Modes 1, 2, and 3.

NextEra stated that deleting the monitor from TS 3.3.3.1 is justified, because TS 3.3.3.6 specifies the appropriate requirements for the monitor [AMI]. NextEra also stated that plant conditions in Modes 4, 5, and 6 are such that the likelihood of an event that would require AMI instrumentation is low; therefore, the AMI instrumentation is not required.

Reasonable assurance of adequate protection cannot be based solely on the probability of the accident occurring or risk. Current TSs like TS 3.4.8, Specific Activity, are APPLICABLE in Modes 1-5, because design basis accidents (i.e., Main Steamline Break, Steam Generator Tube Rupture) can occur in MODES other than 1-3. Therefore, the NRC staff requests that the licensee provide an additional justification why the current APPLICABILITY of ALL MODES should be removed from the TS for the AMI.

SCVB-RAI-1 This RAI is regarding the Proposed Change to Functional Units 5.a.1 and 5.a.2, Control Room East/West Isolation Air Intake Radiation Level.

The following excerpt comes from Page 5 of the Enclosure to the LAR dated July 24,2014 (ADAMS Accession No. ML14209A919).

The control room ventilation system, which includes redundant emergency cleanup subsystems, prevents the buildup of airborne particulates and radioactive iodines in the control room complex during an accident. Two remote air intakes (east and west), with two radiation monitors in each intake, are provided to furnish makeup air to the control room complex.

The following excerpt comes from Page 28, Section 12.3, Revision 15 of the Seabrook Station UFSAR (ADAMS Accession No. ML13134A088 - Document Date April 26, 2013):

Control Room Air Intake Monitors - Channels 6506A and B, 6507A and B Four detectors (Channels 6506A and B, 6507A and B) are located in the east air intake piping and four detectors are located in the west air intake piping. These detectors are located in the Control and Diesel Building. These GM detectors, which are Class 1E, monitor the control room air intake and automatically shut down, on a high radiation signal, the control room ventilation fans and isolation dampers.

Each monitor utilizes a two-out-of-two detector logic such that two detectors must be in alarm before the monitor initiates an isolation signal. These detectors are directly mounted in the air intake stream and do not require shielding.

The LAR details two radiation monitors in each intake. The Updated Final Safety Analysis Report (UFSAR) details four radiation detectors each in both the east and west air intake piping.

Please identify which document is correct.

SCVB-RAI-2 This RAI is regarding the Proposed Change to Functional Unit 2.a - Containment Ventilation Isolation On Line Purge Monitor.

The first paragraph on Page 8 of the Enclosure to SBK-L-14080 to the LAR (ADAMs Accession No. ML14209A919) reads:

The proposed change deletes the on line purge monitor from TS 3.3.3.1 because TS 3.3.2 provides essentially the same requirements for the instrument with the exception of the trip setpoints. However, the setpoint specified in TS 3.3.2, which will be retained in the TS, is more conservative than the setpoint in TS 3.3.3.1 .

The NRC staff notes that the TS 3.3.3.1, Table 3.3-6 Table Notation associated with the Alarm/Trip Setpoint of *reads in its entirety *Two times background; purge rate will be verified to ensure compliance with Offsite Dose Calculation Manual (ODCM) Control C.7.1.1 requirements. With the proposed change to Functional Unit 2.a, the requirement to verify that the purge rate is in compliance with the ODCM Control C.7.1.1 requirements will be deleted.

Please provide the regulatory justification for the deletion of this TS requirement.