ML20101G355
| ML20101G355 | |
| Person / Time | |
|---|---|
| Site: | Seabrook |
| Issue date: | 06/11/1992 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| Shared Package | |
| ML20101G353 | List: |
| References | |
| GL-91-08, GL-91-8, NUDOCS 9206260003 | |
| Download: ML20101G355 (4) | |
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2.MG SEABROOK STATION UNIT 1 umuumammuumuuuum New Hampshire Yankee Facility Operating License NPF-86 Docket No. 50-443 License Amendment Request No. G1-06 Removal of Component Lists From Technical Specifications Generic Letter 91-08
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This License Amendment Request is submitted by New Hampshire Yankee pursuant to 10CFR50.90. The following information is enclosed in support of this License Amendment Request:
. Section 1 Intro 0uction and Description of Proposed Changes
. Section ll Markup of Proposed Changes Section 111 Retype cf Proposed ChangesSection IV Safety Assessment of Proposed ChangesSection V Determination of Significant Hazards for Proposed Changes ~
Section VI Proposed Schedule for License Amendment Issuance and Effectiveness Section Vil Environmental Impact Assessment r
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60 Sworn and Subscribed g
to before me this oo
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,1992 Q
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Ted C. Feigenbaum N
Notary Public President and Chief Executive Officer
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Introduction and Descrintion of Prono ed Channes The purpose of the proposed Technical Specification changes is to i;nplement the guidance of NRC Generic Letter 91-08 'J1gmoval of Component 1 ists From Technical Specifications? Generic Letter 91-08 is intended to improve Technical _ Specifications as it provides an acceptable alternative means to identifying every component by its plant identification number as it is currently listed in the tables of Technical Specifications.
The Technical Specification changes proposed herein by NilY implement the guidance of Generic Lettcr 91-08 by removing the listing of Secondary Containment Bypass Leakage Paths (Technical Specification Table 3.6-1).
The Generic 1.e t t er 91-08 requirements pertaining to removal of the Technical Specification list of Secondary Containment Bypass Leakage Paths are as follows:
Secondary Containment Bynass Lealace Paths The TS on containment leakage includes a list of secondary containment bypass leakage paths; The list identifies these leakage paths by penetration number f or dual containment plants. The combined leakage rate for all penetrations id:ntified as secondary containment bypass leakage paths is specified.
As part of the plant licensing basis, the FSAR defines the penetrations that are secondarv ' otainment bypass leakage paths. This definition of " secondary conti nt bypass leakage paths" is adequate such that the TS requiremn do not require further clarification upon the removal of this list from the TS. Therefore, the TS requirements may be stated in terms of secondary containment bypass leakage paths without further clarification. For example, the limitation of TS 3.6.1.2.c on containment leakage rates should be revised to state lhe following A combined leakage rate of less than or equal to [0.10]
L for all penetrations that are secondary containment bypass icakage paths when pressumired to P.
New. liampshire Yankee has complied with the above guidance of Generic Letter l
91-08 in its proposed changes to Technical Specification 3.6.1.2.c.
/sdditionally, _NIIY p: 3 poses herein to revise - Technical Specification 3.6.3, Containment isolation Valves, to add a footnote that specifies that locked or scaled closed containment isolation valves may be -opened on an intermittent bases under administrative control. New flampshire Yankee currently lists Containment Isolution Valves in its Technical Requirements Manual as discussed below. The-Technical Requirements Manual list of Containment isolation Valves includes the footnote allowing opening of locked or sealed closed valves on an intermittent basis ~ under administrative controls, however this fwtnote is not currently contained in Seabrook Station Technical Specification 3.6.3.
The proposed addition of this footnote to Technical Specification 3.6.3 is recommended by Generic Letter 91-08-_for the purpose of clarifying 'that locked or scaled : closed containment isolation valves are to be' r.onsidered OPERABLE when they are opened on an - intermittent basis under administrative control. With the addition of the -proposed footnote, entry into the Action requirements of Technical Specification 3.6.3 would not be required because
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the locked or scaled closed containment isolation valve is not rendered inoperable by I
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virtue of it being opened intermittently while under administrative control.
N::w Hampshire Yankee has also proposed revisions to Technical Specification Surveillance Requirement 4.6.1.1 as recommended by Generie Letter 91 08 10 reflect that Primary l
Containment Integrity continues to be maintained although a locked:or sealed closed containment isolation valve (s) is opened under administrative control.
New Hampshire Yankee has also proposed changes to ~ the Bases-for; Technical Specification 3.6.3 as recommended by Generic' Letter _91-08.
The proposed changes to the Bases for Technical Specification 3.6.3 define the administrative controls which are required to be implemented when opening a locked or scaled closed containment.
i isolation valve. The following administrative control requirements defined in NHY's l
proposed Bases revision are derived from Generic Letter 91-08:
l The opening of locked or sealed clo.sd containment isolation valves on l
an intermittent basis under administrative control includes the following considerations:
(1) stationing an - operator, who is in constant communication with control room,-at the valve controisi (2) instructing this operator to close these valves in an accident situation, and-(3) assuiing that environmental conditions will not preclude access to close the valves and that this action will prevent the release of radioactivity outside the containment.
l New Hampshire Yankee notes that its Technical Specifications currently reflect some of the specific improvements afforded by Generic Letter 91-08. The Seabrook Station l
Technical Specification improvements previously implemented include the removal of lists for Containment isolation Valves, Containment Penetrr. tion Conductor Overcurrent Protection Devices and Motor-Operated-Valve 7 hermal ' Overload Protection. These lists are contained in NHY's Technical Requirements Manual and are duplicated in the Updated Final Safety Analysis Report. These do'cuments' are j
subject to the change control provisions of the Administrative Controls (Section 6) of the Seabrook Station Technical Specifications. The list of Secondary Containment i
Bypass Leakage Paths which NHY proposes to remove from - the. Technical Specifications will also be added to the Technical Requirements Manual-and the Updated Final Safety Analysis Report.
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- A listing and description of each of the proposed Technical Specification revisions l
included in NHY's License Amendment Recuest 91-06 is provided below:
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Chance Descriotion i
1 vii (Index)
Revision to index to reflect remova'l of Tabih 3.61 " Secondary Containment Bypass Leakage Pat hs."
1 3/4 6-1 Revision to Technical Specification Surveillance Requiremens 4.6.1.la to reflect that primary centainment integrity continues to be maintained when locked or sealed closed containment <
isolation valves are opened.under administrative controls.
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Pace (continued)
Chance Descrintion (continuet i
3/46-2 Revision to Technical Specification 3.6.1.2.'c to l
reflect -the rem. oval of Table 3.6-1 (Secondary j.
Containment Bypass Leakage Paths),
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3/46-5 Table 3.6-1 (Secondary Containment Bypass j
3/466 Leakage Paths) is contained on these pages.
This table is being removed from Technical 4
l Specifications. The new pages will state "PAGE j
INTENTIONALLY BLANK."
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3/4 6-16 Revisions to Technical Specification 3.6.3 adding footnote which allows locked or scaled closed
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containment isolation valves to be opened on an
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intermittent basis under administrative control.
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l Also, the Technical Specification 3 6.3 requirement regarding isolation times *with-isolation times less than or equal to' required '
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isolation times" is deleted as the inservice j
testing requirements referenced by Technical j
Specification 4.0.5 include the veri'ication of valve stroke time = for. containment isolation valves.
l 3/4 6-16 Technical Specification. Surveillance 3/4 6-17 Requirements 4.63.1,. 4.6.3.2, and 4.6.3.3 are revised to improve their specificity by l
identifying that these surv' illances are e
applicable to " containment isolation valves."
i B 3/4 6 3 The 13ases for Technical Specification 3.6.3 is revised to specify the administrative controls l
required when opening locked or sealed closed j
containment -isolation valves.
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' Markup of Pronosed Chances 4
See attached markup ~of proposed changes to Technical Specifications,.
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