ML20214T081
| ML20214T081 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/24/1986 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| SBN-1202, NUDOCS 8609300195 | |
| Download: ML20214T081 (7) | |
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SEABROOK STATION Enginsering Offico e ; ( y) L.,_ I September 24, 1986 Put2c Service of New Hampshire SBN-1202 NEW HAMPSHIRE YANKE8 DIVISION United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter dated August 27, 1986 " Inspection Report No. 50-443/86-27, E. C. Wenzinger to R. J.
Harrison Subj ect :
Response to Inspection Report No. 50-443/86-27
Dear Sir:
Our response to the unresolved items reported in the subject in-spection is provided in Attachment A, included herewith.
Very truly ours, v- ).dMw John DeVincentis Director of Engineering Attachment cci Atomic Safety and Licensind Board Service List Director, Of fice of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, DC 20555 8609300195 860924 PDR ADOCK 05000443 G
pyg It D\\
Seabrook Station Construction Field Offico. P.O. Box 700
- Seabrook, NH 03874
Dline Curran, Isautre Pe ter J. Ma cnews, Mayor a p City McIl Harcon & U2ico 2001 S. Street, N.W.
Nawbu ry por t, MA 01950 Suite 430 Washington, D.C.
20009 Judith H. Mitner Silvergate, Certner, Baker, Sherwin E. Turk Esq.
Fine, Good & Mizner Office of the Executive Legal Director 88 Broad Street U.S. Nuclear Regulatory Commission Boston, MA 02110 Tenth Floor Washington, DC 20555 Calvin A. Canney City Manager Robert A. Backus, Esquire City Hall 116 Lowell Street 126 Daniel Street P.O. Box 516 Portsmouth, NH 03801 Manchester, NH 03105 Stephen E. Merrill, Esquire Philip Ahrens, Esquire Attorney General Assistant Attorney General George Dana Bisbee, Esquire Department of The Attorney General Assistant Attorney General Statehouse Station #6 Office of the Attorney General Augusta, ME 04333 25 Capitol Street Concord, NH 03301-6397 Mrs. Sandra Cavutis Chairman, Board of Selectmen Mr. J. P. Nadeau RfD 1 - Box 1154 Selectmen's Office Kennaington, NH 03827 10 Central Road Rye, NH 03870 Carol S. Sneider, Esquire Assistant Attorney General Mr. Angie Machiros Department of the Attorney General Chairman of the Board of Selectmen One Ashburton Place, 19th Floor Town of Newbury Boston, MA 02108 Newbury, MA 01950 Senator Gordon J. Humphrey Mr. William S. Lord U.S. Senate Board of Selectmen Washington, DC 20510 Town Hall - Friend Street (ATTN:
Tom Burack)
Amesbury, MA 01913 Richard A. Hampe, Eng.
Senator Gordon J. Humphrey Hampe and McNicholas 1 Pillsbury Street 35 Pleasant Street Concord, NH 03301 Concord, NH 03301 (ATIN: Herb Boynton)
Thomas F. Powers, III H. Joseph Flynn, Esquire Town Manager Office of General Counsel Town of Exeter Federal Emergency Management Agency 10 Front Street 500 C Street, SW Exeter, NH 03833 Washington, DC 20472 Brentwood Board of Selectmen Paul McEachern, Esquire RfD Dalton Road Matthew T. Brock, Esquire Brentwood, NH 03833 Shaines & McEachern 25 Maplewood Avenue Gary W. Holmes, Esq.
P.O. Box 360 Holmes & Ells Portsmouth, NH 03801 47 Winnacunnet Ro'ad Hampton, NH 03842 Robert Carrigg Town Office Mr. Ed Thomas Atlantic Avenue FEMA Region I North Hampton, NH 03862 442 John W. McCormack PO & Courthouse Boston, MA 02109
ATTACHMENT A TO SBN-1202 UNRESOLVED ITEMS UNRESOLVED ITEM (86-27-01)
Clarlfy the following two descrepancies.
a.
FSAR design normal containment pressure of 12.1-14.7 psia differs from the Technical Specification containment pressure normal operating band of 14.6-16 psia (Report Section 2.2.3, Item 3).
b.- FSAR containment spray maximum overall system response times either with or without loss of offsite power are substantially dif ferent (longer) than Technical Specification overall system response times (Re port Section 2.3.3, Item 1).
RESPONSE
a.
Chapter 6.2 of the FSAR lists the initial conditions for the limiting containment analyses as 14.6 psia for inadvertent containment spray actuation and 16.2 psia containment response under LOCA conditions.
This agrees with the limits in the Technical Specification.
- Also, Subsection 6.2.1.1.b.5 indicates that the containment is normally operated at a slight positive pressure, and Figure 3.11(B)-1 also lists the normal containment pressure as 0.5 psig (15.2 psia).
Subsection 6.2.1.1.b.5 of the FSAR has never listed the normal containment pressure as being as low as 12.1 psia.
b.
The time response for Containment Spray listed in the Technical Specification is significantly less than the value listed in the FSAR for the following reason. The values in the FSAR include the calculated time for the containment spray piping to fill.
In mon-itoring the time response for containment spray for the Technical Specification surveillance, the time for the piping to fill is not measured.
Hence, the analysis time has been reduced by an appropri-ate amount to account for the pipe fill up time.
This will ensure that safety analysis assumptions are. satisfied.
The Technical Specification values were verified to be achievable iT the per-formance of Startup Test PT 19.2.
UNRESOLVED ITEM (86-27-02)
Address the generic concern that the licensee does not appear to have a method for identifying or permanently assuring that commitments to the NRC remain in effect and are not inadvertently deleted or modified (Report Section 2.5.3, Item 2).
RESPONSE
Seabrook Station " Management-Manual", Section 6.2, Revision 3, has been revised to include steps to provide protection to ensure external regu-latory or operating experience documents, such as I&E Notices, SOERs, SERs, etc., are not altered or inadvertently removed.
ATTACHMENT A TO SBN-1202
( Continued)
UNRESOLVED ITEMS UNRESOLVED ITEM (86-27-03):
4 Discuss the impact of construction site power lines and poles and security light poles in proximity to the SF-6 (offsite power) bus runs with respect to GDC 17 (Report Section 2.5.3, Item 5).
RESPONSE
The overhead construction power line (34.5 kV) which used to cross over the SF6 bus runs has been rerouted so that it no longer crosses the bus runs.
Similarly associated structures with the line in proximity to the bus runs have been removed.
A telephone line which still crosses the SF6 bus runs, will remain in its present location because its size and voltage level does not present a hazard to the SF6 bus runs. The height of the telephone pole for i
this line closest to the bus runs, has been reduced so that its failure cannot impact the bus runs.
Regarding concerns with the security light poles; in the area between the north and south bridges over the SF6 bus runs where a light pole is in close proximity to the bus runs located below grade level, a gal-vanized steel grating is installed over the SF6 bus runs for additional protection of the buses from a falling light pole.
Other light poles along the long bus runs are not considered to present significant hazard to the bus runs because of their distance from the bus runs and their size and light construction.
UNRESOLVED ' 7ZM (86-27-04):
State the current licensee position on the following two items:
a.
Impact of alternate suction piping from the bottom of the con.
densate storage tank to the startup feed pump and failure thereof (Report Section 2.8.3, Item 6).
b.
Need for Technical Specification limits or administrative controls -
on condensate storage tank minimum temperature requirements (Report Section 2.8.3, Item 7).
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ATTACHMENT A TO SBN-1202 (Continued)
UNRESOLVED ITEMS
RESPONSE
a.
Report Section 2.8.3, Item 6, addresses the alternate Startup Feedwater Pump suction line from the Condensate Storage Tank (CST).
Specific mention identified this line as "a plant modification which has been installed but not reflected in the FS AR".
In actuality, the alternate Startup Feedwater Pump suction line is noted in Figure 10.4-4 of the FS AR.
Additionally, FSAR Section 9.2.6.3 addresses this line with respect to its CST nozzle penetra-tion and associated connecting Class 3 pipe.
The connecting pipe from'the CST nozzle "A" is Class 3 Seismic Category I up to and including valve CO-V142. Valve CO-V142 is normally locked closed and provides the required class boundary from the downstream NNS piping to ensure the CST inventory requirements are maintained.
Only in the event the Startup Feedwater Pump is utilized as a backup to the Emergency Feedwater Pumps, will valve CD-V142 be opened to supply the Startup Feedwater Pump.
F3AR Section 10.4.7.2.(a) states "all Condensate System connections to the CST are located above the tank level required for emergency plant shutdown (see Subsection 9.2.6)".
The Condensate System connections are those required for normal system operation. Although the alternate Startup Feedwater Pump suction line penetrates the CST within approximately two (2) feet from the tank bottom, this line
.normally remains' isolated and should not be considered available for normal system operation. As a clarification to the above, FSAR Section 10.4.7.2.(a) will be modified as reflected in Attachment (1).
J i
Report Section 2.8.3, Item 6, repeatedly refers to the alternate Startup Feedwater Pump suction line as a plant modification. The subject line was not installed as a backfit.
This line is part of 4
the original CST design and construction effort.
b.
FSAR Section 9.2.6.5.d states that "A local tank thermocouple in conjunction with a temperature control loop controls the condensate transfer pump and a steam control valve to maintain water temperature at 50*F minimum".
Temperature element CO-TE-4080 senses condensate storage temperature and provides input to temperature control valve CO-TCV-480, to main-tain CST temperature above 50*F.
CO-TE-4080 also provides input-to-computer alarm D4122 to alarm CST low temperature. As part of the alarm response procedure for D4122, Operations will log CST temp-erature daily to verify that tank temperature does not drop below 50*F.
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ATTACRMENT A TO SBN-1202 (Continued)
UNRESOLVED ITEMS UNRESOLVED ITEM (86-27-05):
Describe corrective action regarding the emergency boration lines which appeared to exit a haat-controlled environment without heat tracing (Report Section 2.9.3, Item 3).
RESPONSE
Report Section 2.9.3, Item 3, addresses a minimum 65*F temperature limit for CVCS lines containing a 4 weight percent boric acid concentration.
There was specific mention of " emergency boration lines through valves CS-V426 and CS-V442 which appear to exit the 65'F controlled environ-ment and are not heat t rac ed".
Per isometrics 1-CS-471-01 and 1-CS-453-02, both subject valves and adjacent upstream lines are located in the 65*F controlled environment as referenced by the Service Environ-mental Chart [FS AR 3. ll(B)-1, Sht. 3]. Valv'es CS-V442 and CS-V426 pro-vide normally closed Class 2 to Class 3 boundary isolations which isolate the CVCS boric acid lines from the charging pump suction lines. As s pe ci-fled in FSAR Section 9.3.4.3.f, the required CVCS lines and components containing a 4% wt. boric acid concentration are located in a controlled-temperature environment.
UNRESOLVED ITEM (86-27-06):
State the licensee ' position with regard to the tolerances established by the Instrument Department calibration procedures which appear to conflict with the finite limits provided by the Technical Specification LCO's and surveillance requirements (Report Section 2.10.3, Item 1).
RESPONSE
Specifications 2.2.1 and 3.3.2 require the Reactor Trip and ESFAS set-points be set consistent with the trip setpoint values shown in Tables 2.2-1 and 3.3-4,~respectively.
As long as the instrument channel is lef t at or around the trip setpoint _within the band allowed in the setpoint study for the calibration accuracy of the final device, it is consistent with the trip setpoint and in compliance with the Technical Specification.
This position is derived f rom the Westinghouse (W) Protection System Setpoint Study (PSSS).
The W PSSS quantifies the possible errors associated with the instrument channel and combines. them statistically to determine an overall error.
The setpoint is then established by starting with the safety analysis limit and subtracting or adding the overall error as appropriate so that the setpoint is conservative with regard to the safety analysis limit. As long as the final d'evice is left within the assumed cali-bration accuracy, it has satisfied the assumptions of the setpoint methodology.
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ATTACHMENT A TO SBN-1202 (Continued)
UNRESOLVED ITEMS The W methodology was reviewed and accepted by the NRC in the licensing for V. C. Summer, D. C. Cook, and North Anna among others.
(Refer to RAI 420.08). Also the Seabrook SER Section 7.3.2.13 indicates that the NRC has reviewed and approved the W methodology.
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