SBK-L-14184, Supplement to LAR 13-05, LAR 14-01, LAR 14-02 and LAR 14-03 in Response to Issuance of Amendment 141, Risk-Informed Justifications for Relocation of Specific Surveillance Frequency Requirements to Surveillance Frequency Control Program

Supplement to LAR 13-05, LAR 14-01, LAR 14-02 and LAR 14-03 in Response to Issuance of Amendment 141, Risk-Informed Justifications for Relocation of Specific Surveillance Frequency Requirements to Surveillance Frequency Control Program

ML14349A646
Person / Time
Site:	Seabrook
Issue date:	12/11/2014
From:	Dean Curtland NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-14184
Download: ML14349A646 (16)

Text

NExTera ENERGY.P December 11, 2014 SBK-L-14184 Docket No. 50-443 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station Supplement to NextEra Energy Seabrook, LLC's LAR 13-05, LAR 14-01, LAR 14-02 and LAR 14-03 in Response to Issuance of Amendment 141, Risk-Informed Justifications for the Relocation of Specific Surveillance Frequency Requirements to the Seabrook Surveillance Frequency Control Program (SFCP)

References:

1. NextEra Energy Seabrook, LLC License Amendment Request (LAR) 13-05, Fixed Incore Detector System Analysis Methodology, dated August 8, 2013 (ML13260A160)

2. NextEra Energy Seabrook, LLC License Amendment Request (LAR) 14-01, Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF)

Traveler -523, "Generic Letter 2008-01, Managing Gas Accumulation," Using the Consolidated Line Item Improvement Process,.dated June 24, 2014 (ML14177A503)

3. NextEra Energy Seabrook, LLC LAR 14-02, Proposed Change to Increase Voltage Limit for Diesel Generator Load Rejection Surveillance Requirement, dated July 24, 2014 (ML14209A918)

4. NextEra Energy Seabrook, LLC LAR 14-03, Changes to Technical Specification 3.3.3.1, Radiation Monitoring for Plant Operations, dated July 24, 2014 (ML14209A919)

5. NRC letter, Issuance of Amendment Regarding the Risk-Informed Justifications for the Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program, dated July 24, 2014 (ML13212A069)

Subsequent to the submittal of the above license amendment requests (LARs) (References 1-4),

the NRC issued License Amendment 141 (LA 141) (Reference 5) to the Seabrook Station Operating License. LA 141 incorporated relocation of specific surveillance frequency requirements from the Seabrook Technical Specifications (TS) to the Seabrook Surveillance Frequency Control Program (SFCP).

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

,4001

U.S. Nuclear Regulatory Commission SBK-L-14184/Page 2 This letter is being submitted to provide revised, marked-up TS pages for LAR 13-05, LAR 14-01, and LAR 14-02 that include the changes made in LA 141. No revised, marked-up TS pages are required for LAR 14-03 as LA 141 eliminated in its entirety, Table 4.3.3 (on Page 3/4 3-39).

LA 141 had no direct impact on the proposed changes in LAR 13-05, LAR 14-02 and LAR 14-03 in that surveillance frequencies were not affected by those LARs. The revised marked-up pages for LAR 13-05 and LAR 14-02 (Attachments l and 3, respectively) now include the revised wording regarding surveillance frequencies approved in LA 141. The mark-ups indicate the changes made by LA 141.

Consistent with TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation," LAR 14-01 revised and added new surveillance requirements that require verification that locations susceptible to gas accumulation in the Emergency Core Cooling, Residual Heat Removal, and Containment Spray systems are sufficiently filled with water. At the time LAR 14-01 was submitted, NextEra did not have a Surveillance Frequency Control Program (SFCP); therefore, LAR 14-01 proposed surveillance frequencies of 31 days. However, subsequent to submittal of LAR 14-01, NextEra implemented a SFCP as approved in LA 141.

This supplement revises the frequencies for the proposed new and revised surveillance requirements included in LAR 14-01 from 31 days to "in accordance with the Surveillance Frequency Control Program." TSTF-523 discusses that for licensees without a SFCP, the frequency will be 31 days. For licensees with a SFCP, the frequency will be "In accordance with the Frequency Control Program." NextEra has implemented a SFCP; therefore, the modifications to the proposed frequencies for the surveillance requirements in LAR 14-01 are appropriate and consistent with TSTF-523. The revised marked-up pages for LAR 14-01 are provided in Attachment 2.

The modifications to the proposed changes are administrative in nature and do not alter the conclusions in References 1, 2, 3 and 4 that the proposed changes do not involve a significant hazard consideration pursuant to 10 CFR 50.92.

The Station Operation Review Conmmittee has reviewed this supplement to LAR 13-05, LAR 14-01, LAR 14-02, and LAR 14-03.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Mr. Michael Ossing, Licensing Manager, at (603) 773-7512.

U.S. Nuclear Regulatory Commission SBK-L-14184/Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 2014.

Sincerely, NextEra Energy Seabrook, LLC Dean Curtland Site Vice President cc:

NRC Region I Administrator J.G. Lamb, NRC Project Manager, Project Directorate 1-2 NRC Senior Resident Inspector Mr. Perry Plummer 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, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 to SBK-L-14184 Revised Marked-Up Technical Specification Pages for LAR 13-05, Fixed Incore Detector System Analysis Methodology, dated August 8, 2013

POWER DISTRIBUTION LIMITS HEAT FLUX HOT CHANNEL FACTOR - F_(Z)

SURVEILLANCE REQUIREMENTS 4.2.2.1 The provisions of Specification 4.0.4 are not applicable.

4.2.2.2 FQ(Z) shall be evaluated to determine if FQ(Z) is within its limits by:

a.

Using the incore detectors to obtain a power distribution map at any THERMAL POWER greater than 5% of RATED THERMAL POWER.

b.

Increasing the measured FQ(Z) component of the power distribution map by 3%

to account for manufacturing tolerances and further increasing the value by 5%

when. usm the rmoveable irerm deteetem OFr 5.21% when usirmg the fixed inMrefflI deteet to account for measurement uncertainties.

c.

Satisfying the following relationship:

RTP Fm(Z) < FQ xK(Z) for P > 0.5 P x W(Z)

RTP Fm(Z) < F K(x for P < 0.5 0.5 x W(Z) where Fma(Z) is the measured FQ(Z) increased by the allowances for manufacturing tolerances and measurement uncertainty, FRP is the FQ limit, K(Z) is the normalized FQ(Z) as a function of core height, P is the relative THERMAL POWER, and W(Z) is the cycle dependent function that accounts for RTP power distribution transients encountered during normal operation. F Q, K(Z),

and W(Z) are specified in the COLR.

d.

Measuring Fm(Z)according to the following schedule:

1) Upon achieving equilibrium conditions after exceeding by 20% or more of RATED THERMAL POWER, the THERMAL POWER at which FQ(Z) was last determined*, or

2)

In accordance with the Surveillance Frequency Control Program, whichever,,<

occurs first.

t-[

Revised bV LA 141

• During power escalation at the beginning of each cycle, power level may be increased until a power level for extended operation has been achieved and a power distribution map obtained.

SEABROOK - UNIT 1 3/4 2-6 Amendment No. 33, -76, 444-to SBK-L-14184 Revised Marked-Up Technical Specification Pages for LAR 14-0 1, Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler -523, "Generic Letter 2008-01, Managing Gas Accumulation," Using the Consolidated Line Item Improvement Process

REACTOR COOLANT SYSTEM REACTOR COOLANT LOOPS AND COOLANT CIRCULATION HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required reactor coolant pump(s), if not in operation, shall be determined OPERABLE in accordance with the Surveillance Fre uency Control Program by verifying 4-correct breaker alignments and indicated power ava ility.

4.4.1.3.2 The required steam generator(s) shall be d ermined OPERABLE by verifying secondary-side water level to be greater than or equal to 14% in accordance with the Surveillance Frequency Control Program.

Revised by LA 141 4.4.1.3.3 At least one reactor coolant or RHR loop shall be verified in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program. -

4.4.1.3.4 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

SEABROOK - UNIT 1 3/4 4-5 Amendment No. 44-:-

REACTOR COOLANT SYSTEM REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation*, and either:

a.

One additional RHR loop shall be OPERABLE**, or

b.

The secondary-side water level of at least two steam generators shall be greater than 14%.

APPLICABILITY: MODE 5 with reactor coolant loops filled***.

ACTION:

a.

With one of the RHR loops inoperable and with less than the required steam generator water level, immediately initiate corrective action to return the inoperable RHR loop to OPERABLE status or restore the required steam generator water level as soon as possible.

b.

With no RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to retum the required RHR loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required 2

shall be determined to be within limits in accordance with the Surveillance Frequency ControL-V

• ,=

Program.

Revised by LA 141

=

4.4.1.4.1.2 At least one RHR loop shall be determined to be ifon and circulating t

reactor coolant in accordance with the Surveillance Frequency e"ontrol Program.

The RHR pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided: (1) no operations are

=" permitted that would cause dilution of the Reactor Coolant System boron concentration and (2) core outlet temperature is maintained at least 1 00F below saturation temperature.

=*

• • One RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the C. " other RHR loop is OPERABLE and in operation.

• • • A reactor coolant pump shall not be started unless the secondary water temperature of each steam generator is less than 50OF above each of the Reactor Coolant System cold-leg temperatures.

SEABROOK - UNIT 1 3/4 4-6 Amendment No.-4--

I

REACTOR COOLANT SYSTEM REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN - LOOPS NOT FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two residual heat removal (RHR) loops shall be OPERABLE* and at least one RHR loop shall be in operation.**

APPLICABILITY: MODE 5 with reactor coolant loops not filled.

ACTION:

a.

With less than the above required RHR loops OPERABLE, immediately initiate corrective action to return the required RHR loops to OPERABLE status as soon as possible.

b.

With no RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required RHR loop to operation.

SURVEILLANCE RQUIREMENTS Revised blyLA 141 4.4.1.4.2 At least one RHR loop shall be determined to b loperation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.4.2.1 Verify required RIR loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Freauencv Control Program.

• One RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop is OPERABLE and in operation.

"The RHR pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided: (1) no operations are permitted that would cause dilution of the Reactor Coolant System boron concentration and (2) core outlet temperature is maintained at least 10°F below saturation temperature.

SEABROOK - UNIT 1 3/4 4-7 Amendment No.-441--

EMERGENCY CORE COOLING SYSTEMS ECCS SUBSYSTEMS - T, GREATER THAN OR EQUAL TO 350OF SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Progr m by verifying,h that the following valves are in the indicated positions with p r to the valve operators removed:

Valve Number Valve Function Valve Position SI-V-3 Accumulator Isolation Open*

SI-V-17 Accumulator Isolation Open*

SI-V-32 Accumulator Isolation Open*

SI-V-47 Accumulator Isolation Open*

SI-V-1 14 SI Pump to Cold-Leg Isolation Open Revised by LA 141 RH-V-14 RHR Pump to Cold-Leg Isolation Open RH-V-26 RHR Pump to Cold-Leg Isolation Open RH-V-32 RHR to Hot-Leg Isolation Closed RH-V-70 RHR to Hot-Leg Isolation Closed SI-V-77 SI to Hot-Leg Isolation Closed SI-V-102 SI to Hot-Leg Isolation Closed S

b.

In accordance with the Surveillance Frequency Control Program by:

2)

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, se le or otherwise secured in position, is in its correct position.

c.

By a visual inspection which verifies oose debris (rags, trash, clothing, 0etc.)

is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

1)

For all accessible areas of the containment prior to establishing primary CONTAINMENT INTEGRITY, and

2)

At least once daily of the areas affected within containment by T

containment entry and during the final entry when primary CONTAINMENT INTEGRITY is established.

• Pressurizer pressure above 1000 psig.

j

,ASEABROOK

- UNIT 1 3/4 5-5 Amendment No. 30, 58, 6*,-444-I **Not required to be met for system vent flow paths opened under administrative control.]

CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.1 Two independent Containment Spray Systems shall be OPERABLE with each Spray System capable of taking suction from the RWST* and automatically transferring suction to the containment sump.

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

ACTION:

With one Containment Spray System inoperable, restore the inoperable Spray System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 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 />; restore the inoperable Spray System to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be 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 4.6.2.1 Each Containment Spray System shall be demonstrated OPERABLE:

a.

INSERT 1 b

Next Page Li.

In accordance with the Surveillance Frequency Control Progi thAt eseh valve (mantllu, peVwer -*pated, er autematie) in t.l vaFifying. 10, RA*h that is nut ;uuruexi. sealedu, 9F~i~wt tt~ANG99

.. ue II; 199IE19 IS Ii 6i9 urret By verifying OPERABILITY of each pump when tested pursuant to N

Specification 4.0.5; I

Revised by LA 141 In accordance with the Surveillance Frequency Control Program during shutdown, by:

1)

Verifying that each automatic valve in the flow path actuates to its correct position on a Containment Pressure-Hi-3 test signal, and

2)

Verifying that each spray pump starts automatically on a Containment Pressure-Hi-3 test signal.

d.

By verifying each spray nozzle is unobstructed following activities that could result in nozzle blockage.

• In MODE 4, when the Residual Heat Removal System is in operation, an OPERABLE flow path is one that is capable of taking suction from the refueling water storage tank upon

,,being manually realigned.

I SEABROOK - UNIT 1 3/4 6-14 Amendment No. 3 0T,90, 4 2-8, 44 1 4 -

INSERT 1

1. Verifying that each valve (manual, power operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position is in its correct position**,

and

2. Verifying Containment Spray locations susceptible to gas accumulation are sufficiently filled with water.

INSERT 2

• • Not required to be met for system vent flow paths opened under administrative control.

REFUELING OPERATIONS 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation.*

APPLICABILITY: MODE 6, when the water level above the top of the reactor vessel flange is greater than or equal to 23 feet.

ACTION:

With no RHR loop OPERABLE and in operation, suspend all operations involving an increase in the reactor decay heat load or a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required RHR loop to OPERABLE and operating status as soon as possible. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.9.8.1 At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2750 gpm in accordance with the Surveillance Frequency Control Program.-

Revised by LA 141 4.9.8.1.1 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

• The RHR loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour period during the performance of CORE ALTERATIONS in the vicinity of the reactor vessel hot legs.

SEABROOK - UNIT 1 3/4 9-8 Amendment No. 444-

REFUELING OPERATIONS RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent residual heat removal (RHR) loops shall be OPERABLE, and at least one RHR loop shall be in operation.*

APPLICABILITY: MODE 6, when the water level above the top of the reactor vessel flange is less than 23 feet.

ACTION:

a.

With less than the required RHR loops OPERABLE, immediately initiate corrective action to return the required RHR loops to OPERABLE status, or to establish greater than or equal to 23 feet of water above the reactor vessel flange, as soon as possible.

b.

With no RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required RHR loop to operation. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.9.8.2 At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2750 gpm in ccordance t

P Surveillance Frequency Control Program."<

rRevised by LA 141 4.9.8.2.1 Verify required R-HR loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

• Prior to initial criticality, the RHR loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour period during the performance of CORE ALTERATIONS in the vicinity of the reactor vessel hot legs.

SEABROOK - UNIT 1 3/4 9-9 Amendment No. 444-to SBK-L-14184 Revised Mark-Up Technical Specification Pages for LAR 14-02, Proposed Change to Increase Voltage Limit for Diesel Generator Load Rejection Surveillance Requirement

I ELECTRICAL POWER SYSTEMS A.C. SOURCES OPERATING SURVEILLANCE REQUIREMENTS 4.8.1.1.2 (Continued)

f.

In accordance with the Surveillance Fre ency Control Program, during shutdown by:

"*'1 Revised bv LA 141

1)

(NOT USED)

2)

Verifying the generator capability to reject a load of greater than or equal to 671 kW while maintaining voltage at 4160 + 420 volts and frequency at 60 + 4.0 Hz;

3)

Verifying the generator capability to reject a load of 6083 kW without tripping. The generator voltage shall not exceed '4:74 volts during and I

following the load rejection;

4)

Simulating a loss-of-offsite power by itself, and:

a)

Verifying deenergization of the emergency busses and load shedding from the emergency busses, and b)

Verifying the diesel starts from standby conditions #W on the loss of offsite power signal, energizes the emergency busses with permanently connected loads within 12 seconds, energizes the auto-connected shutdown loads through the emergency power sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 +/- 420 volts and 60 +/- 1.2 Hz during this test.

5)

Verifying that on an SI actuation test signal, without Ioss-of-offsite power, the diesel generator starts from standby conditions### on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The generator voltage and frequency shall be greater than or equal to 3740 volts and 58.8 Hz within 10 seconds after the auto-start signal; the steady-state generator voltage and frequency shall be maintained at 4160 +/- 420 volts and 60 +/- 1.2 Hz during this test;

1. 1. Selected surveillance requirements, or portions thereof, may be performed during conditions or modes other than shutdown, provided an evaluation supports safe conduct of that surveillance in a condition or mode that is consistent with safe operation of the plant. (Ref. NRC GL 91-04)

1. 1. 1. Starting of the diesel for Specifications 4.8.1.1.2f.4) and 4.8.1.1.2f.5) may be performed with the engine at or near normal operating temperature.

SEABROOK - UNIT 1 3/4 8-5 Amendment No. 54, 7*4, 73,.--,444-