ML20217M377

Proposed Tech Specs 3.7.6 Re Control Room Emergency Makeup Air & Filtration Subsystem

ML20217M377
Person / Time
Site:	Seabrook
Issue date:	03/27/1998
From:	NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
Shared Package
ML20217M338	List: ML20217M330 ML20217M367 ML20217M377
References
NUDOCS 9804080088
Download: ML20217M377 (8)

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MARKUP OF PROPOSED CHANGES Refer to the attached markup of the proposed changes to the Technical Specifications. The r attached markup reflects the currently issued revision of the Technical Specifications listed L

below. Pending Technical Specifications or Technical Specification changes issued subsequent -

l' to this submittal are not reflected in the enclosed markup.

The following Technical Specification is included in the attached markup:

! Technical Specification Iille Page(s) g

. TS 3.7.6 Control Room Emergency 3/4716-

Makeup Air and Filtration Subsystem l

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Page 4 9804080008 980327 PDR ADOCK 05000443 P PDR

PLA... SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY MAKEUP AIR AND FILTRATION SUBSYSTEM LIMITI'GN CONDITION FOR OPERATION 3.7.6 Two independent Control Room Emergency Makeup Air and Filtration Subsystems shall be OPERABLE.

APPLICABILITY: All MODES ACTION:

MODES 1, 2, 3 and 4:

With one Control Room Emergency Makeup Air and Filtration Subsystem inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODES 5 and 6:

a. With one Control Room Emergency Makeup Air and Filtration Subsystem inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE

_ontrol Room Emergency Makeup Air and Filtration Subsyster.; in the filtration / recirculation mode.

b. With both Control Room Emergency Makeup Air and Filtration Subsystems inoperable, or with the OPERABLE Control Room Emergency Makeup Air and Filtration Subsystem, required to be in the filtration / recirculation mode by ACTION a., not capable of being powered by an OPERABLE emergency power _sourcet suspend all operations involving CORE ALTERATIONSJr posiitiv reactivi Ll - - - -

SURVEILLANCE REOUIREMENTS 4.7.6 Each Control Room Emergency Makeup Air and Filtratio1 Subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room is maintained below the limiting equipment qualification temperature in the control room area,

b. At least once per 31 days on a STAGGERED TEST BASIS by initiating,

, from the control room, flow through the HEPA filters and charcoal l

adsorbers and verifying that the system operates for at least 10 continuous hours with the heaters operating; SEABROOK - UNIT 1 3/4 7-16

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. .bl. . REIYPE OF PROPOSED CHANGES .

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Refer to the attached retype of the proposed ' changes to the Technical Specifications. The-attached retype reflects the currently issued version of the Technical Specifications. Pending l

Technical Specification changes or Technical Specification changes issued subsequent to this  !

submittal are not reflected in the enclosed retype. The enclosed retype should be checked for j continuity with Technical Specifications prior to issucnce. i e

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PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY MA.KEUP AIR AND FILTRATION SUBSYSTit 1 -

LIMITING CONDITION FOR OPERATION l 3,7.6 Two independent Control Room Emergency Makeup Air and Filtration l Subsystems shall be OPERABLE.

APPLICABILITY: All MDDES ACTION:

MODES 1, 2, 3 and 4:

l With one Control Room Emergency Makeup Air and Filtration Subsystem inoperable, restore the ino)erable system to OPERABLE status within 7 days or be in at least HOT STAND 3Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODES 5 and 6:

a. With one Lontrol Room Emergency Makeup Air and Filtration Subsystem inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE l Control Room Emergency Makeup Air and Filtration Subsystem in the filtration / recirculation mode.

b. With both Control Room Emergency Makeu] Air and Filtration Subsystems inoperable, or with the OPERABLE Control Room Emergency Makeup Air and Filtration Subsystem. required to be in the l filtration / recirculation mode by ACTION a. not capable of being powered by an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS.

SURVEILLANCE REOUIREMENTS 4.7.6 Each Control Room Emergency Makeup Air and Filtration Subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room is l maintained below the limiting equipment qualification temperature in the control room area.

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b. At least once per 31 days on a STAGGERED TEST BASIS by initiating,  !

from the control room, flow through the HEPA filters and charcoal  !

adsorbers and verifying that the system operates for at least 10 {

continuous hours with the heaters operating: '

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i IV. DETERMINATION OF SIGNIFICANT IIAZARDS FOR PROPOSED CIIANGES 1 4

License Amendment Request (LAR) 08-07 proposes to modify the action requirements as presently contained in Technical Specification 3.7.6, " Control Room Emergency Makeup Air l and Filtration". Currently, the action for both trains of CREMAFS inoperable in Modes 5 and 6 i requires the suspension of all operations involving core alterations or positive reactivity changes.

The proposed change will modify the existing requirement by eliminating the restriction of suspending positive reactivity changes.

l In accordance with 10 CFR 50.92, North Atlantic has reviewed the attached proposed change and has concluded that it does not involve a significant hazards consideration (SHC). The basis for j the conclusion that the proposed change does not involve a SHC is as follows:

1. The prcposed change does not involve a signficant increase in the probability or consequences cfan accidentpreviously evaluated.

The proposed changes have no impact on the probability or consequences of an accident previously evaluated in the UFSAR. The control room ventilation systems are support ,

systems which have a role in the detection and mitigation of accidents but do not l contribute to the initiation of any accident previously eva!=ted. The removal of the i positive reactivity addition restriction in Mode 5 and 6 has no impact on the course of any accidents previously evaluated. There are no presently evaluated positive reactivity or boron dilution accidents that credit the CREMAFS to mitigate its consequences or provide radiological protection. The positive reactivity restriction is overly restrictive in that it does not allow cooldown below 200 F when Mode 5 is entered as a result of both I trains of CREMAFS being inoperable nor does it allow Reactor Coolant System I temperature to vary.

The restriction is also redundant to Technical Specification 3.1.1.2 " Reactivity Control Systems Shutdown Margin- Tm less than or equal to 200 F"in Mode 5 and Technical Specification 3.9.1 " Refueling Operations Boron Concentration" in Mode 6. Technical l Specification 3.1.1.2 action, with shutdown margin less than the limit specified in the l Core Operating Limits Report or with the Reactor Coolant System boron concentration less than 2000 ppm boron, requires immediate and continued boration until the restoration of the required shutdown margin or boron concentration. Similarly, Technical Specification 3.9.1 actions require suspension of core alterations or positive reactivity changes in addition to immediate and continued boration until the restoration of the required shutdown margin (K,n) or boron concentration while in Mode 6.

Sufficient shutdown margin ensures that (1) the reactor can be made suberitical from all operating conditions,(2) the reactivity transients associated with the postulated accident conditions are controllable within acceptable limits and (3) the reactor will be maintained sufficiently subcritical to preclude inadvertent criticality in the shutdown condition. The above referenced reactivity control system specifications provide the necessary protection for postulated reactivity addition accident conditions. Therefore, modifying the Technical Specification action that requires the suspension of positive reactivity changes and core alterations with both trains of the CREMAFS inoperable Page 6

i does not involve a significant increase in the consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of accidentfrom anypreviously anal):ed.

The proposed change that removes the positive reactivity addition restriction in Mode 5 and 6 does not create the possibility of a new accident nor does it create the possibility of a difTerent kind of accident previously evaluated. There are no presently evaluated positive reactivity or boron dilution accidents that credit the CREMAFS to mitigate its consequences or provide radiological protection. The addition of positive reactivity during the above described situation is overly restrictive and furthermore redundant to Technical Specification 3.1.1.2 " Reactivity Control Systems Shutdown Margin- T.,, less than or equal to 200 F" in Mode 5 and Technical Specification 3.9.1 " Refueling Operations Boron Concentration" in Mode 6. The above referenced reactivity control system specifications provide the necessary protection for postulated reactivity addition accident conditions. Therefore, modifying the Technical Specification action that requires the suspension of positive reactivity changes and core alterations with both trains of the CREMAFS inoperable does not create the possibility of a new or different accident from any previously evalaated.

3. The proposed change does not involve a significant reduction in the margin ofsafety.

The changes being proposed do not revise equipment design or operation nor do they make changes to Technical Specification required safety limits or safety system settings, in addition, they do not alter the environmental conditions which are to be maintained in the control room during normal operation and following an accident and they do not revise the accident analyses. Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Based on the above evaluation, North Atlantic concludes that the activities associated with the proposed changes satisfy the no significant hazards consideration of 10CFR50.92(c) and, accordingly, a no significant hazards consideration finding isjustified.

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V. . PROPOSED SCHEDULE FOR LICENSE AMENDMENTISSUANCE AND '

EFFECTIVENESS North Atlantic requests NRC review of LAR 98-07 and issuance of a license amendment by September 30,'1998, having immediate effectiveness and implementation required within 60 days; i

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VI. , hNVIRONMENTAL IMPACT ASSESSMENT

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- North Atlantic has reviewed the proposed license amendment against the criteria 'of 10CFR51.22 i

for environmental considerations.' . He proposed changes do not involve a significant hazards 1 consideration, nor increase the types and' amounts of effluent that may be released offsite, nor ]

significantly increase individual or cumulative occupational radiation exposures. Based on the

- foregoing, North Atlantic concludes that the proposed change meets the criteria delineated in - .l j

10CFR51.22(c)(9) for a categorical exclusion from the requirements for. an Environmental l

. Impact Statement.

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