ML20204A428
| ML20204A428 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/06/1986 |
| From: | George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| References | |
| SBN-1029, NUDOCS 8605120206 | |
| Download: ML20204A428 (19) | |
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-o Gecr;;e S. Thomas yk;o Preycent-Nuclear Production Put2c Service of New Hampshire New Hampshire Yankee Division May 6, 1986 SBN-1029 T.F. B7.1.2 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Mr. Vincent S. Noonan, Project Director PWR Project Directorate No. 5
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos.
50-443 and 50-444.
(b) USNRC Letter dated March 13, 1986, "Seabrook Technical Specificarfons," V. S. Noonan to R. J. Harrison (c) PSNH Letter (SBN-1012) dated April 22, 1986, "Seabrook Proof and Review Technical Specifications," G. S. Thomas to V. S. Noonan Subj ect: Justification for Comments on Seabrook Station Proof and Review Technical Specifications
Dear Sir:
As requested by your staff enclosed please find the justifications for our comments provided in Reference (c).
Should you have any questions regarding this matter, please contact Mr. Warren J. Hall at (603) 474-9574, extension 4046.
Very truly yours, da
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. Thomas GST/cj b Enclosure cc: ASLB Service List 860512O206 860506 PDR ADOCK 05000443 A
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I P.O. Box 300 Seabrook 103874 - Telephone (603)474-9521
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JUSTIFICATIONS SECTION 1.0 1.
Section 1.8 - Clarifies the method to be used by Seabrook for measuring controlled leakage.
2.
Section 1.10 - This definition added to describe the testing of actual digital signals.
3.
Section 1.29 - Clarifies definition and makes it consistent with the specification.
4.
Section 1.31 - Site Boundary - Additional clarification in order for the definition to apply to the gaseous effluent dose calculations.
5.
Section 1.31 - Unrestricted Area - A specific definition was needed to address liquid effluent dose calculations.
6.
Section_1.42 - Seabrook Station plant specific information.
J JUSTIFICATIONS SECTION 2.0 1.
Sections 2.1.1 & 2.1.2 - The I hour time limit to be in ROT STANDBY increases the likelihood of human error causing an unnecessary plant trip or some other state of less safe plant conditions.
Investigation and discussion has found that when operating at full power, the minimum time to reach HOT STANDBY is about 50 to 55 minutes. Forcing a MODE change that takes almost the entire allowable time places undue pressure on the operator and increases the probability of a potential error creating more unnecessary problems.
2.
Table 2.2 Seabrook Station specific plant data.
3.
Page B 2 Provides clarification of the sentence.
4.
Page B 2 Not applicable to Seabrook.
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JUSTIFICATIONS SECTION 3/4.1 1.
~ Specification 4.1.1.1.'l.3 (footnote) - The requirement to consider the most reactive rod to be fully withdrawn is applicable when credit is being taken for withdrawn rods to meet shutdown. margin requirements, i.e., during critical operation. However, in those instances when all rods are known to be fully inserted, the requirement to assume the most reactive rod in withdrawn -constitutes an unnecessary burden on plant operations and the needless processing of primary coolant.
2.
Specification 4.1.1.2.b (footnote) - The requirement to consider the most reactive rod to be fully withdrawn is applicable when credit ' is being taken for withdrawn. rods to meet shutdown margin requirements, i.e.,
during critical operation. However, in those instances when all rods are known to be fully inserted, the requirement to assume the most reactive rod is withdrawn constitutes an unnecessary burden on plant operations and the needless processing of primary coolant.
3.
Specification 4.1.2.3.1 - Seabrook Station plant specific data.
4.
Specification 4.1.2.3.2 - Provides clarification for surveillance and operation as a result of the Seabrook cold overpressure mitigation analysis.
5.
Specification 4.1.2.4.1 - Seabrook Station plant specific data.
6.
Specification 3.1.2.6.b - Seabrook Station plant specific data.
7.
Specification 3.1.2.7 - The changes cade to this specification more accurately define the system and its appropriate configuration in the applicable modes.
8.
Specification 3.1.3.1 (Action b.3.d) - This change is made to allow operation above 75% of RATED THERMAL POWER once it has been determined that accident analysis and peaking factor evaluation supports operation above 75%.
.9.
Specification 3.1.3.2 (A'ction a.1) - This chang'e is made because once the initial position determination is made within the first 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, once per f
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereaf ter is more 'than adequate to detect a misaligned rod.
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Specification 3.1.3.4 - The change f rom 3.3 to 2.2 is provided by
-Westinghouse analysis. The addition of word to (a) provides consistency with other areas of the Tech Specs.
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a' JUSTIFICATIONS SECTION 3/4.2 I
'l.
Specification 3.2.1 - Added to provide reference to appropriate durveillance requirement.
i 2.
Specifications 3.2.5 (footnote) and 4.2.5.4 - These changes are made to allow entering MODE I to perform the required surveillance.
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JUSTIFICATIONS SECTION 3/4.3 1.
Table 3.3-1, Page 3/4 3-2 (6a) - This change made to account for the 4 channels available with the Seabrook Gamma Metrics system.
2.
Table 3.3-1, Page 3/4 3-2 (9 & 11) - This change necessary to comply with Seabrook specific design.
3.
Table 3.3-1, Page 3/4 3-3 (14) - This note not applicable to Seabrook design.
4.
Table 3.3-1, Page 3/4 3-3 (16b) - Typo, should be 4 for minimum channels operable.
5.
Table 3.3-1, Page 3/4 3-4 (18e) - This interlock only applicable in MODE 1.
6.
Table 3.3-1, Page 3/4 3-5 (##) - Should be below P-6, not above P-7.
7.
Table 3.3-1, Page 3/4 3-5 (#f f) - Should be below P-10, not above P-10.
8.
Table 3.3-1, Page 3/4 3-5 (Action 2) - This change made to implement WCAP-10271 and Supplement 1.
9.
Table 3.3-1, Page 3/4 3-6 (Action 5) - This change made since we have Specification 3.1.2.7 that covers boron dilution events.
10.
Table 3.3-1, Page 3/4 3-6 (Actions 6 & 7) - This change made to implement WCAP-10271 and Supplement 1.
11.
Table 3.3-1, Page 3/4 3-7 (Action 11) - This change made to implement WCAP-10271 and Supplement 1.
12.
Table 4.3-1, Page 3/4 3-10 (1) - Typo, should be 13, not 14.
13.
Table 4.3-1, Page 3/4 3-10 (2 - 12) - These changes made to implement WCAP-10271, Supplement I and Supplement 2.
14.
Table 4.3-1, Page 3/4 3-11 (13,14, 15~& 16) - These changes made to implement WCAP-10271, Supplement I and Supplement 2.
15.
Table 4.3-1, Pages 3/4 3-13 & 3.4 3-14 (1, 9,16, & 17) - These changes made to implement WCAP-10271, Supplement I and Supplement 2.
16.
Table 4.3-1, Page 3/4 3-13 (8) - If the refueling outage testing is implemented, this note is not needed.
17.
Table 3.3-3, Page 3/4 3 This provides consistency with Seabrook design.
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-JUSTIFICATIONS SECTION 3/4.3 (Continued) i 18.
Table 3.3-3, Page 3/4 3-21 (7e) - Note in specification is self-explanatory.
19.
Table 3.3-3, Page 3/4 3-22 (10b & c) - These changes are made to make the specification plant specific.
-20.
Table 3.3-3, Page 3/4 3-23 (**) - Not applicable to Seabrook.
21.
Table 3.3-3, Page 3/4 3-23 (Actions 13, 14 & 15) - These changes made to implement WCAP-10271, Supplement I rad Supplement 2.
22.
Table 3.3-3, Page 3.3 3-34 (Actions 18, 20, & 22) - These changes made to implement WCAP-10271, Supplement I and Supplement 2.
23.
Table 3.3 All changes in this table are made as a result of plant specific requirements.
24.
Table 3.3 All changes made as a result of review of plant specific design.
25.
Table 4.3 All changes made as a result of WCAP-10271, Supplements 1 and 2.
26.
Tables 3.3-6 and 4.3 All changes made to make this table Seabrook specific.
27.
Specification 4.3.3.2 - As agreed with Merv Dunenfeld from February 28, 1986 meeting, this surveillance can be deleted.
28.
Specification 4.3.3.3.2 - These changes made per manufacturer's requirements and to clarify the surveillance.
29.
Specification 3.3.3.5, 4.3.3.5.1, & 4.3.3.5.2 - Changes made to comply with plant specific documentation and terminology.
30.
Table 3.3 This table marked to be plant specific.
31.
Surveillance 4.3.3.6 - This change made to account for deletion of Hydrogen Monitoring Specification 3.6.4.1 and 4.6.4.1.
32.
Table 3.3 This table changed to be plant specific.
.33.
Specification 3.3.3.9 - These changes are made to make this specification consistent with changes in action statement.
8 JUSTIFICATIONS SECTION 3/4.3 (Continued) 34.
Specification 3.3.3.10 - These changes made to make the specification consistent with the changes in the action statement.
35.
Tables 3.3-13 and 4.3 These changes made to be plant specific.
36.
Turbine Overspeed Protection - NHY has proposed deletion of this specification. It would be replaced with a Reliability Program. These changes are made to be consistent with the FSAR design description.
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JUSTIFICATIONS SECTION 3/4.4 1
1.
Specification 4.4.3.2 - This change made because two banks of pressurizer heaters are permanently powered from an emergency power source. A 92 day l
surveillance interval is unusually short. Heaters are not designed to change drastically in power output over an 18 month time frame.
Additionally, this surveillance test is time consuming and involves personnel hazard.
2.
Specification 3.4.7 (footnote) and Table 3.4.2 - This change made to conform to Westirghouse chemistry requirements.
3.
Table 4.4 This information completes the table.
4.
Specification 3.4.9.3 - This change made as a result of system reanalysis.
5.
Specification 3.4.11 - This change made to clarify wording.
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JUSTIFICATIONS SECTION 3/4.5 1.
Specification 3.5.1 - Seabrook Station plant specific data. This changes the allowed outage time to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, which will allow most repairs to accumulators to be completed before requiring a shutdown.
In addition, ac umulators are needed in accident analysis only for large LOCA which is a relatively unimportant risk contributor. The standard 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance interval is too frequent, occupying operator time and attention unnecesarily. Also, the operator will respond to alarms and indications.
2.
Specification 3.5.2 (Action a) - This changes the allowed outage time to 7 days, which will allow most repairs to be accomplished before requiring a shutdown. Also, the extended allowed outage time does not significantly affect ECCS system reliability.
3.
Specification 3.5.2 (footnote) ~ This change is made to allow for placing pumps in service or taking pumps out of service at the MODE change. This change is a result of the Seabrook analysis.
4.
Specification 4.5.2.1 - The standard 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance interval is too frequent, occupying operator time and attention unnecessarily. Also, the operator will respond to alarms and indications.
5.
Specification 4.5.2.f - Changes made due to Westinghoune analysis.
6.
Specification 4.5.3.2 and footnote - This change made as a result of the COMS analysis for Seabrook Station.
7.
Specification 3.5.3.2 - This specification most be added.
8.
Specification 3.5.4 - Seabrook Station plant specific data, i
JUSTIFICATIONS SECTION 3/4.6 1.
Specification 4.6.1.1.c - This change made to reflect the latest analysis.
2.
Specification 3.6.1.2 and Action - Changes made to reflect latest analysis.
3.
Specification 4.6.1.2 - Changes made to reflect latest analysis and also to delete those surveillance requirements that do not apply to Seabrook.
4.
Specifications 3.6.1.3, 4.6.1.3 and footnote - Changes made to reflect latest analysis and to clarify that operable airlock door may be opened for entry to repair an.. inoperable inner door.
5.
Specifications 3.6.1.7, Actions, 4.6.1.7.2 and 4.6.1.7.4 - These specifications are changed to reflect the latest analysis and to provide the ability to open 8 inch containment purge valves as necessary. for operation and not be restricted to 1000 hrs / calendar year.
6.
Specification 3.6.2.1 - This changes the allowed outage time to 7 days
- which will allow most repairs to be completed before requiring a
. shutdown. Also, the allowed outage time does not significantly reflect the Containment Spray System reliability.
7.
Specification 4.6.2.1 - Seabrook Station plant specific data.
8.
Specification 4.6.4.2 - The system function test frequency was changed to every 18 months to avoid unnecessary cycling of equipment.
9.
Specifications 3.6.4.3 and_4.6.4.3 - Seabrook Station plant specific data.
10.
Specification 4.6.5.1 - The 15 minutes is acceptable since this system does not have heaters. The other changes in the surveillance relate to plant specific data.
11.
Specification 3.6.5.2 - The allowed outage time was changed to 7 days to reflect the low risk significance of the enclosure building. A detailed I
evaluation of this change will be provided in the risk based analysis to i
be submitted in mid August.
12.
Specification 4.6.5.2 - To clarify the surveillance to show Seabrook does not have serfes access doors.
13.
Specification 3.6.5.3 - The allowed outage time was changed to 7 days to reflect the low risk significance of the enclosure building. A detailed evaluation of this change will be provided in the risk based analysis to be submitted in mid August.
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JUSTIFICATIONS SECTION 3/4.7 1.
Specification 3.7.1.2' and Surveillances These changes made to have this specification reflect the actual design of the Seabrook Emergency Feedwater System.
2.
Specification 3.7.1.3 and Surveillances - These changes made to have this specification reflect the actual design of.the Seabrook system. The way this specification is currently written would require several plant operating configurations which cannot be achieved.
3.
Specification 4.7.3.b.2 - This change made to make the surveillances conform to Seabrook specific design.
4.
Specification 4.7.4.b.2 - This change made to make the surveillances conform to Seabroo'k specific design.
15.
Specifications 3.7.5 and 4.7.5 - These changes are made to more accurately describe the UHS and its appropriate surveillance requirements.
6.
Specification 3.7.8.1 - These changes made to clarify the specification for the fire suppression system.
7.
Specification 4.7.8.1.1.d - ANI has accepted a yearly frequency for system flush.
8.
Specification 4.7.8.1.2.a and b - Plant specific change due to analysis, and a clarification of the method for testing fuel oil to be consistent with Specification 3.8.1.1.
9.
Specification' 3.7.8.2 - An update of the areas covered by the spray and sprinkler systems.
10.
Specification 3.7.10 - These changes provide the Seabrook specific data and table for this specification.
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JUSTIFICATIONS SECTION 3/4.8 1.
Specification 3.8.1.1.b - Plant specific numbers.
2.
Specification 3.8.1.1 (Action) - The 7 days is requested as Technical Specification improvement effort. The additional changes are made as a result of the ongoing NRC and industry effort to improve the reliability of the diesel generators.
3.
Specification 4.1.1.1.2.b - No engine mounted fuel tank at Seabrook. The change to daily is sufficient to assure no accumulation of water in the fuel tanks.
4.
Specification 4.8.1.1.2.d.l.d - This addition made to assure proper quality of fuel oil during the survefilance testing.
5.
Specification 4.8.1.1.2.d.2 - This addition made to require additional testing-if initial surveillance is failed.
6.
Specification 4.8.1.1.2.e.3-This change made to clarify the inspection process.
7.
Specification 4.8.1.1.2.f.7 - The bases section of the Tech Specs explains the technical reasons for not starting the diesel at operating temperature with an auto-start signal. Therefore, we call out Surveillance Requirement 4.8.1.1.2.f.14 rather than f.6.b.
8.
' Specification 4.8.1.1.2.f.14 - There is no reason or justification for this to be in the Technical Specifications. This is an FSAR commitment for startup only, not a requirement for Tech Specs.
9.
Specification 3.8.1.2 - Plant specific numbers.
10.
Specification 3.8.2.1 - This section changed to be plant specific for Seabrook Station 4 battery DC System.
11.
Specification 3.8.3.1 - This change made to clarify the bus tiea.
12.
Specification 3.8.3.2 - Changes made to make the specification specific to Seabrook design.
13.
Specification 3.8.3.3 - Specification added because of SER commitment.
14.
Specification 3.8.4.1 - Changes made for clarification and also to allow for use of circuits during operation, if necessary.
JUSTIFICATIONS SECTION 3/4.8 (Continued) 15.
Specification 4.8.4.2.a.1 - The penetration withstand times are much longer than motor protection times. This clarifies which time in Table 3.8-1 we have to meet. Also, called out specific action to be taken if penetration withstand time is acceptable but motor protection time fails. Also, added overload devices and clarified test surveillance.
16.
Specification 4.8.4.2.a.2 - Clarification for testing of breakers and overload devices.
17.
Specification 3.8.4.3 and 4.8.4.3 - Seabrook does not have bypass devices. The surveillance requirements have been changed to reflect NRC acceptance of the Seabrook philosophy of replacing thermal overload devices with pre-calibrated devices.
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JUSTIFICATIONS' SECTION 3/4.9 1.
Specification 3.9.1.3 - This specification not needed due to existing Specification 3.1.2.7.
2.
Specification 3.9.2 (Action a) - Core alterations should be allowed to continue if one source range channel is operable and a temporary detector
.is operable with containment or control room operation.
3.
- Specification 3/4.9.6 - Plant specific Seabrook number.
4.
Specifications 4.9.8.1 and 4.9.8.2 - Plant specific Seabrook number.
5.
Specifications 3.9.12 and 4.9.12 - These changes made to make the specification specific to the Seabrook design and the FSAR analysis.
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JUSTIFICATIONS SECTION 3/4.10 1.
Specification 3.10.2 and Surveillances - Deletion of the requirement to flux map is based on the fact that the specific tests that might invoke this Special Test Exception are done such that full core flux maps are of little or no value.
1.
Rod worth and rod drop time testing is done at HZP.
2.
Dropped, stuck and ejected rod worth tests require the performance of flux mapping to _ verify test predictions and are performed at 50%
power or less.
3.
Incore/excore calibrations are usually performed within the confines of Specification 3.2.1 and its ACTION statement a.2.a.2.
Only on an infrequent basis will incore/excore calibrations be performed under this test exception. In either case quarter-core flux mapping is performed every 2-4% change in AFD as part of the test procedure.
Furthermore full core mapping with the core in an AFD transient would produce questionable results due to the length of time involved.
2.
Specification 3.10.4 and Surveillances - USNRC Regulatory Guide 1.68 Rev. 2 requires RCCA drop testing to be performed at hot and cold, full flow and no flow conditions in order to bound the situations where a scram might occur. The current Technical Specifications only allow the required pumps to be de-energized for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Since one hour is not enough time to acquire a complete set of RCCA drop times, compliance with the Reg. Guide requires multiple unnecessary start-stop cycles on the reactor coolant pumps ' and/or the residual heat removal pumps.
In order to facilitate the required start-up testing, Special Test Exceptions 3.10.4.1 should be extended to apply to Sections 3.4.1.2, 3.4.1.3, and 3.4.1.4.
Testing performed within the restrictions of T.S. 3.10.4.1 will not result in increased risk to the core or the public.
JUSTIFICATIONS SECTION 3/4.11
'I.
Specification 3/4.11.1 - The change is made to this specification to reference the PCP because Seabrook Station will utilize an asphalt solidification system and.all.the appropriate surveillances are' covered by the PCP.
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JUSTIFICATIONS SECTION 5.0 1.
Items 5.1.3 and 5.1.4 were added to satisfy the ' requirements of the RETS.
2.
All. other marked-up data in this Section is Seabrook specific data.
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4 JUSTIFICATIONS SECTION 6.0 1.
Section 6.3 - These changes made to clarify Seabrook specific training methods.
2.
Section 6.4.2 - These changes made to reflect the Seabrook NSARC charter.
3.
Section 6.7.4 - Seabrook does not have hydrogen recocbiners outside of the containment.
4.
Section 6.8.1.3 - This is being deleted and shall be contained in the ODCM.
5.
Section 6.8.1.4 - This is being deleted and shall be contained in the ODCM.
6.
Section 6.8.1.5 - This requirement already included in the annual report.
7.
Section 6.12.2 - These changes made to comply with plant specific procedures and assignment of personnel.
8.
Section 6.13.2 - These changes made to this section to reflect proposed changes to 3/4.11 and 3/4.12 by adding them to the ODCM and deleting same from the Technical Specifications.
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