ML15131A338
| ML15131A338 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/05/2015 |
| From: | John Lamb Plant Licensing Branch 1 |
| To: | Dean Curtland NextEra Energy Seabrook |
| Lamb J, NRR/DORL/LPLI-2, 415-3100 | |
| References | |
| TAC MF4572 | |
| Download: ML15131A338 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Dean Curtland, Site Vice President clo Michael Ossing Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874 June 5, 2015
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 (ADAMS) Accession No. ML14209A919), as supplemented by two letters dated December 11, 2014 (ADAMS Accession Nos. ML14349A644 and ML14349A646, respectively), NextEra Energy Seabrook, LLC (NextEra or the licensee) submitted 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 May 11, 2015 (ADAMS Accession No. ML15147A674), 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 revised draft of these questions was previously sent to Mr. Mike Ossing of your staff on June 1, 2015 (ADAMS Accession No. ML15152A310), 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.
On June 3, 2015, a conference call was held to clarify the RAI and Mr. Gary Kilby of your staff agreed that NextEra would respond to the RAI within 30 days of the date of the letter. 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 1 O CFR, Section 2.108, "Denial of application for failure to supply information."
If you have any questions, please contact me at (301) 415-3100.
Docket No. 50-443
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv
. Lamb, Senior Project Manager icensing Branch 1-2 Divi on of Operating Reactor Licensing Offi e of Nuclear Reactor Regulation
1.0 SCOPE 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 By letter dated July 24, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14209A919), as supplemented by two letters dated December 11, 2014 (ADAMS Accession Nos. ML14349A644 and ML14349A646, respectively), NextEra Energy Seabrook, LLC (NextEra or the licensee) requested a license amendment request (LAA) to change the Technical Specifications (TSs) for Seabrook Station, Unit 1 (Seabrook). The proposed LAA 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-RAl-3 NUREG-0800, Standard Review Plan (SAP) 15.0.1, "Radiological Consequence Analyses Using Alternative Source Terms," dated July 2000 (ADAMS Accession Number ML003734190),
states, in part that:
The methodology and assumptions for calculating the radiological consequences should reflect the regulatory positions of RG [Regulatory Guide] -1.183.
Appendix B of RG-1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," dated July 2000 (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. This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples), the height of the drop, and the compression, torsion, and shear stresses on the irradiated fuel rods. Damage to adjacent fuel assemblies, if applicable (e.g., events over the reactor vessel), should be considered.
Enclosure Updated Final Safety Analysis Report (UFSAR) Section 15.7.4.3 states:
The FHA [fuel handling accident analysis] dose consequence analysis is consistent with the guidance provided in RG 1.183 Appendix B, "Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident.
The proposed change to the applicability of TS 3.3.3.1, "Radiation Monitoring for Plant Operations," (i.e. Table 3-6, Functional Units 5.a.1 and 5.a.2) from requiring the operability of the control room air intake radiation monitors from "All" Modes to include "during movement of irradiated fuel" does not address movement of loads other than "irradiated fuel assemblies" over the spent fuel pool. For example, Section 15.7.4.1 of the UFSAR considers dropping new fuel assemblies. Section 15.7.4.1 states that:
Dropping or damaging an assembly [not an irradiated assembly] within the Fuel Storage Building (FSB) is another postulated accident addressed in this analysis.
It is unclear how the proposed revised applicability for Functional Units 5.a.1 and 5.a.2 are derived from the Seabrook FHA analysis and how the FHA analysis bounds Regulatory Guide 1.183, Regulatory Position 1.1. To clarify, how does the FHA analysis determine the most limiting control room dose and how does the FHA analysis show that the limiting control room dose is not the drop of a new fuel assembly or loads 1 other than a recently irradiated fuel assembly assuming no credit2 for the control room intake monitors? Please provide enough detail (inputs, assumptions and methodology) so that the NRC staff can independently verify the results of the FHA. Alternatively, change the Applicable Modes of TS 3.3.3.1, Table 3.3-6, Functional Units 5.a.1 and 5.a.2 to include "during movement of fuel assemblies and loads3 over irradiated fuel."
1 Loads is consistent with the terminology in the current Seabrook technical specifications (See Technical Specifications 3.8.1.2).
2 Regulatory Guide 1.183, Regulatory Position 5.1.2 states that credit may be taken for accident mitigation features that are classified as safety-related and are required to be operable by technical specifications. The control room intake monitors are not required to be operable by technical specifications during the movement of new fuel assemblies and other loads and, therefore, would not be credited in the fuel handling accident safety analysis.
3 Loads not covered under the "Heavy Loads" program.
ML15131A338 OFFICE LPL 1-2/PM LPL 1-2/LA NAME JLamb ABaxter DATE 05/22/15 05/15/15 Sincerely, IRA/
John G. Lamb, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsNrrDorl Resource RidsNrrLAABaxter Resource RidsNrrDorlDpr Resource RidsAcrsAcnw MailCTR Resource LPLl-2 R/F
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LPL 1-2/BC LPL 1-2/PM UShoop DBroaddus JLamb 06/01/15 06/04/15 06/05/15