ML20198E729
| ML20198E729 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/16/1998 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | |
| Shared Package | |
| ML20198E716 | List: |
| References | |
| NUDOCS 9812240134 | |
| Download: ML20198E729 (6) | |
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i SEABROOK STATION UNIT 1
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.p; t;ggyOperatingLice_nseNPF-86l '
.m t Docket No. 50-443 alj
.,j Lic'ense Awiend men't Request NU 98215 i
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' 2"Rebcation'of TS 3/4.7.10," Area Temperature Monitoring,".J 4
, n; /,s iTo The Techolcal Requirements Manual" t
j This License Amendment Realest is submitted by North Atlantic Energy Service Corporation
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pursuant to 10CFR50.90. The following information is enclosed in support of this L! cense Ainendment Request:
Section 1 Introductionand Safety Assessmentfor Proposed j
Changes l
l Section 11 Markup of Proposed Changes e
Section lli Retype of Proposed Changes e
Section IV Determination of Significant Hazards for Proposed Changes e
Section V Proposed Schedule for License Amendmentissuance and Effectiveness e
Section VI Environmentallmpact Assessment Sworn and Subscribed before me this h
/d day o(UM//4
.1998
//AAII Ted C. Feigenbaum Notary Public ExecutiveVice Pre. dentand Chief NuclearOfficer 1
9812240134 981216
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PDR ADOCK 05000443 P
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Section i Introduction and Safety Assessment for the Proposed Change Page1
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INTRODUCTION AND SAFETY dSSESSMENT OF TIIE PROPOSED CII ANGE A.
Introduction License Amendment request (LAR) 98-15 proposes a change to the Seabrook Station Technical Speci6 cations on the basis of the NRC's " Final Policy Statement on Technical Specification improvements for Nuclear Power Reactors"(58 FR 39312), issued in July 1993, and; the results of the NRC Staff review of WCAP-11618, "Mathodically Engineered, Restructured and improved Technical Specifications, Merits Program - Phase 11 Task 5, Criteria Application," including Addendum 1, as documented in a letter dated May 9,1988 to R. A. Newton, Chairman of the Westinghouse Owners Group (generically referred as the NRC STS Split Report). The proposed change involves the relocation of Technical Specification (TS) 3/4.7.10, " Area Temocrature Monitoring," and associated TS Table 3.7-3, to the Seabrook Station Technical Requirements Manual (SSTR). The SSTR is referenced in the Seabrook Station Updated Final Safety Analysis Report and is the implementing manual for the Technical Specification Improvement Program referenced in Section 6.7 of the Technical Specifications.
The NRC's " Final Policy Statement on Technical Specifications improvements for Nuclear Power Reactors" provided a specific set of four (4) objective criteria to determine which of the design conditions and associated surveillances should be located in the TSs as limiting conditions for operation.
The Final Policy Statement noted that implementation of these additional criteria, as amended to 10 CFR 50.36, may cause some requirements presently in TSs to no longer merit inclusion in TSs. The NRC STS Split Report, Apper. dix B, Table 2," Westinghouse Standard Technical Specifications LCOs Which May Be Relocated," speciGeally references the Area Temperature Monitoring LCO as meriting relocation (to a licensee-controlled document).
The Seabrook Station Technical Requirements Manual (SSTR) is a licensee-controlled document which contains certain technical requirements and is the implementing manual for the Technical Specification improvement Program referenced in Section 6.7 of the Technical Specifications. Changes to these requirements are reviewed and approved in accordance with Seabrook Station Technical Speci0 cations, Section 6.7, and as outlined in the SSTR. Speci6cally, changes to the Technical Requirements require a 10 CFR 50.59 safety evaluation and are reviewed and approsed by the Station Operations Review Committee (SORC) and the Nuclear Safety Audit Review Committee (NSARC) prior to implementation.
Note: The SSTR does not provide provision for incom, c on of bases information, thercfore, the associated Bases for TS 3/4.7.10 will be deleted anc J not be incorporated into the SSTR.
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1 B.
Safety Assessments of The Proposed Change In November 1987, the Westinghouse Owners Group submitted to the NRC Staff, WCAP-il618,
" Methodically Engineered, Restructured and Improved Technical Specifications, Merits Program - Phase 11 Task 5, Criteria Application." The topical report applied the Commission's screening criteria to the Westinghouse Standard Technical Specifications (NUREG-0452, Revision 4 and drafl Revision 5). The NRC Staff documented the results of their review of WCAP-11618 in a letter dated May 9,1988 to R. A.
Newton, Chairman of the Westinghouse Owners Group. Among the Specifications to which the screening criteria were applied was Standard TS 3/4.7.13, Area Temperature Monitoring. Based upon that application, the following detemiination was made:
Area temperature monitoring is not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Thus, Area Temperature Monitoring does not satisfy Criterion 1 (as amended in 10 CFR 50.36) for retention; Area temperature monitoring is not a process variable that is an initial condition of a Design Basis Accident (DBA) or Transient Analysis that assumes either the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, Area Temperature Monitoring does not satisfy Criterion 2 (as amended in 10 CFR 50.36) for retention; Area temperature monitoring is not a structure, system or component (SSC) that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, Art Temperature Monitoring does not satisfy Criterion 3 (as amended in 10 CFR 50.36) for retention; Based upon a Probabilistic Risk Assessment (PRA) Summary report for the MERITS Program contained in Section 4 of WCAP-ll618, Area Temperature Monitoring was not identified as a significant risk contributor. Therefore, Area Temperature Monitoring does not satisfy Criterion 4 (as amended in 10 CFR 50.36) for retention in the Technical Specifications.
Area temperature limits for Seabrook Station have been established to ensure that environmentally qualified equipment will not be exposed to temperatures beyond that which they were originally qualified. These limits and their corresponding plant locations are presently contained in Seabrook Station TS 3/4.7.10. The consequences of exceeding the area temperature limits are that extended exposure to elevated temperatures could contribute to equipment degradation that exceeds the rate
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assumed by the Seabrook Station Environmental Qualification (EQ) Program.
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The North Atlantic EQ program is described in the Seabrook Station Equipment Qualification (SSEQ)
Manual and Updated Final Safety Analysis Report (UFSAR), Sections 3.11 and 7.5. The EQ program is based on the requirements and guidelines of 10 CFR 50.49, " Environmental Qualification of Electric j
Equipment important to Safety for Nuclear Power Plants," 10 CFR 50, Appendix A, General Design Criterion 4, " Environmental and Missile Design Bases," NUREG-0588, Revision 1, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," Institute of Electrical and Electronics Engineers (IEEE) Standard IEEE-323-1974, " Qualifying Class IE Equipment for Nuclear Power Generating Stations," Regulatory Guide 1.97, Rev. 3, " Instrumentation for Light-Water Page 3
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l Cooleci Nuclear Power Plants to Assess plant and Environs Condition During and Following an Accident," SECY-81-119, and UFSAR Sections 3.11 and 7.5.
Adherence to the UFSAR and regulatory documents is controlled by ensuring that any changes to the EQ program, including the affected equipment or changes in the plant environment, are documented through North Atlantic's Design Change Request (DCR) and Minor Modification (MMOD) process. In compliance with the DCR / MMOD process, changes to the EQ program or engineering evaluations that affect the EQ program are reviewed pursuant to the requirements of 10 CFR 50.59. In addition, North Atlantic's policies and procedures ensure that other processes such as corrective and preventative maintenance activities, as well as new procedures and procedure changes are reviewed for equipment qualification technical accuracy.
Specific to temperature monitoring, the EQ program also employs a procedure, EQ 2.4, " Ambient Temperature Verification," that provides instructions of incorporating methods to monitor and track actual component temperatures (or ambient temperatures for self-heating components) of selected equipment on the liarsh Environment Equipment List having a qualified life of less than 40-year design life due to temperatures to which it is exposed.
Relocating TS 3/4.7.10 to the Technical Requirements Manual will still provide adequate controls for area temperature in those areas designated in TS Table 3.7-3. The relocated requirements of TS 3/4.7.10 I
to the Technical Requirements Manual will continue to be administratively controlled in accordance with TS Section 6.0," Administrative Controls".
The Seabrook Station Technical Requirements Manual is a licensee-controlled document which contains certain technical requirements and is the implementing manual for the Technical Specification Improvement Program. Changes to these requirements are reviewed and approved in accordance with Seabrook Station Technical Specifications. Section 6.7, and as outlined in the Technical Requirements Manual.' Specifically, changes to the Technical Requirements require a 10 CFR 50.59 safety evaluation and are reviewed and approved by the Station Operations Review Committee (SORC) and the Nuclear Safety Audit Review Committee (NSARC) prior to implementation.
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In conclusion, the requirements or area temperature monitoring do not need to be controlled by TS f
because (1) their inclusion in TS is not specifically required by 10 CFR 50.36, or other regulations,(2) the requirements are not required to avert r.n immediate threat to the public health and safety, (3) Area Temperature Monitoring was not identified as a significant risk contributor, based upon the Probabilistic Risk Assessment (PRA) Summary report for the MERITS Program contained in Section 4 of WCAP-11618, and (4) changes to these requirements will be adequately controlled by the provisions pursuant to 10 CFR 50.59 to determine if an unreviewed safety question (USQ) exists which, if a USQ exists, will j
require NRC Staff approval prior to implementation.
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Section II Markup of Proposed Changes The attached markups reflects the currently issued revision of the Technical Specifications listed below.
Pending Technical Specifications or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed markup.
. The following Technical Specifications are included in the attached markup:
Technical Specification Title Page(s) 3/4.7.10 & Table 3.7-3 Index Page (Area Temperature Monitoring) viii B 3/4.7.10 Index Page (Area Temperature Monitoring) xi 3/4.7.10 Area Temperature Monitor,:g 3/4 7-23 Table 3.7-3 Area Temperature Monitoring 3/4 7-24 B 3/4.7.10 Area Temperature Monitoring B3/47-5 Page 5
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