ML23317A125
| ML23317A125 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/03/2023 |
| From: | Strand D NextEra Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML23317A044 | List:
|
| References | |
| L-2023-152 | |
| Download: ML23317A125 (1) | |
Text
November 3, 2023 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Seabrook Station NEXTera ENERGY~
SEABROOK 10 CFR 50.59(d)(2) 10 CFR 50.71(e) 10 CFR 54.37(b)
Docket 50-443 L-2023-152 10 CFR 50.59 Report, Revision 22 to the Seabrook Station Updated Final Safety Analysis Report, Revision 19 to "Fire Protection Safe Shutdown Capability (1 0CFR50, Appendix R),"
Revision 20 to "Evaluation and Comparison to BTPAPCSB 9.5-1, Appendix A", Revision 168 to the Technical Requirements Manual, 10 CFR 54.37(b) Aging Management Review Summary, and Summary of Commitment Changes NextEra Energy Seabrook, LLC (NextEra) encloses the 10 CFR50.59 Report, Revision 22 to the Seabrook Station Updated Final Safety Analysis Report (UFSAR), Revision 19 to "Fire Protection Safe Shutdown Capability (1 0CFR50, Appendix R)," Revision 20 to "Evaluation and Comparison to BTP APCSB 9.5-1, Appendix A" and Revision 168 to the Technical Requirements Manual. The 10 CFR 50.59 Report and the UFSAR are submitted pursuant to the requirements of 10 CFR 50.59(d)(2) and 10 CFR 50. 71 (e). The 10 CFR 50.59 report covers the period from January 1st, 2022, through June 30th, 2023. UFSAR Revision 22 incorporates approved and implemented design changes and UFSAR changes identified from January 1st, 2022, through June 30th, 2023. The incorporated changes to the UFSAR have been reviewed in accordance with 1 0 CFR 50.59.
The reviews determined that these changes did not require prior NRC approval. The Aging Management Review Summary is pursuant to 10 CFR 54.37(b).
The Summary of Commitment Changes covers the period of January 1st, 2022, through June 30th, 2023.
The UFSAR is provided in its entirety on CD-ROM in Portable Document Format (PDF). The List of Effective Pages contained within the UFSAR provides a listing of each page and its revision number with a revision bar indicating which pages contain changes. The controlled drawings referenced in the UFSAR are not being provided as they have the potential to contain security-related information. The drawings are available on site for NRC review. The Fire Protection Safe Shutdown Capability Report, Evaluation and Comparison to BTP APCSB 9.5-1 Report and the Technical Requirements Manual are also provided on CD-ROM.
NextEra Energy Seabrook, LLC PO Box 300, Seabrook, NH 03874
U.S. Nuclear Regulatory Commission L-2023-152 I Page 2 The summaries of 10 CFR 50.59 evaluations for design changes incorporated in Revision 22 of the UFSAR are attached as Enclosure 1. Enclosure 2 is a listing of UFSAR Change Requests (UFCRs) incorporated in UFSAR Revision 22 during the reporting period. The affected Sections,
'Tables and Figures are provided for each UFCR. Enclosure 3 contains UFCRs incorporated in the Fire Protection Safe Shutdown Capability Report. Enclosure 4 provides the UFCRs incorporated in Evaluation and Comparison to BTP APCSB 9.5-1 Report. Enclosure 5 contains UFCRs incorporated in the Technical Requirements Manual. contains a report describing how the effects of aging of newly-identified structures, systems or components {SSCs) will be managed, as required by 10 CFR 54.37(b). Enclosure 7 provides a summary of Regulatory Commitment Changes.
One copy of the UFSAR revision on CD-ROM is being submitted to the Document Control Desk, Washington, DC, along with a copy to the Region I Regional Office and a copy to the Resident Inspector at Seabrook Station.
Should you have any questions regarding this submission, please contact Mr. Kenneth Mack, Fleet Licensing Manager, at 561-904-3635.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on November 3rd, 2023.
Sincerely, Dianne Strand General Manager Regulatory Affairs Florida Power & Light cc:
NRC Region I Administrator NRC Project Manager, Project Directorate 1:-2 NRC Senior Resident Inspector Enclosed CD Listing:
CD 1, 40 files - UFSAR CD 2, 3 files -- Appendix A, Appendix R, TRM
Seabrook St.ation 10 CFR 50.59 Report, Revision 22 to the Seabrook Station Updated Final Safety Analysis Report, Revision 19 to "Fire Protection Safe Shutdown Capability (10CFR50, Appendix R)," Revision 20 to "Evaluation and
- Comparison to BTP APCSB 9.5-1, Appendix A" and Revision 168 to the Technical Requirements.Manual, 10 CFR 54.37(b)Aging Management Review Summary, and Summary of Commitment Changes Page 1 of 1 to L-2023-152 Summary Report of Facility Changes, Tests, and Experiments Completed in Accordance with the Requirements of 10CFR50.59 for Revision 22 of the Updated Final Safety Analysis Report
Design Change Evaluations Design changes documented in the following Engineering Changes (EC) were installed during the period covered by the 10 CFR 50.59 Report. A 10 CFR 50.59 evaluation was performed for the ECs identified below. For each of the evaluations performed, there were no activ.ities requiring prior NRC approval identified.
10 CFR 50.59 Evaluation 21-001 Summary Description and
Purpose:
EC 295498, Containment Analysis Update For Heat Exchanger Calibration This activity updates the Seabrook Containment Analysis to correct heat exchanger calibration errors. Cases using the ocean as the ultimate heat sink are added to demonstrate that the Cooling Tower is more limiting for long term temperature and pressure considerations.
Additional tube plugging and fouling considerations are included with additional runs to more conservatively model maximum PCCW temperatures. The long term 100 day run is modified to maintain the steam enthalpy constant which is consistent with the approach in the input tables.
Evaluation Summary:
This activity updates the Seabrook Containment Analysis to correct heat exchanger calibration errors. Cases using the ocean as the ultimate heat sink are added to demonstrate that the Cooling Tower is more limiting for long term temperature and pressure considerations. This change re-runs a UFSAR Chapter 15 described analysis to verify design functions are met for the following changes_:
- 1. Correcting heat exchanger input parameters. Correcting the heat exchanger inputs, and the linked calibrations result in slightly enhanced containment heat removal (i.e. lower pressures and temperatures). Additional heat removal slightly increases the piping temperatures, but all are within previous analysis temperatures. The affected piping temperatures are beyond the level of the detail of the UFSAR Chapter 6 and do not require a UFSAR update.
- 2. Adding ocean cases to validate the cooling tower cases are bounding for containment heat removal. The ocean analysis results in less restrictive containment conditions. The piping temperatures are within the previously analyzed limits which are below the detail described in the UFSAR so do not require a UFSAR update. Therefore, this aspect is not adverse and therefore screens out.
- 3. Adding sensitivity cases with various tube plugging and fouling parameters to challenge piping temperatures. This change results in more challenging support system temperatures. This change does not impact limiting containment peak temperature and pressure. The additional fouling and tube plugging cases impact piping temperatures which are not described in UFSAR Chapter 6 so do not require a UFSAR update. The Page 1 of 3
additional cases are bounded by margins and other cases in the pipe temperature analyses.
- 4. Making the 100 day long term enthalpy model consistent with the mass and energy release calculation. The results are bounded by (i.e. more benign) than the Composite LOCA I MSLB curve shown in the Service Environment Chart. Additionally, the Composite LOCA curve energy EQ energy deposition bounds the analysis results. The containment pressure reduction to less than half the peak remains within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the accident.
A 10 CFR 50.59 evaluation is required because this update requires re-performing an UFSAR described analysis to verify design functions are met and is therefore adverse.
10 CFR 50.59 Evaluation 22-001 Summary Description and
Purpose:
EC 297206, Revise Tr 23 To Extend Turbine Valve Testing Interval This EC revises Technical Requirement 23 to change the frequency for testing the High Pressure Turbine Stop Valves from once/90 days to Once/150 days and the frequency for testing the LP Turbine CIVs to once/120 days, and revises Section 3.5 to reflect the changes resulting from the application of the MPR evaluation to extend the testing interval.
Evaluation Summary:
This 50.59 Evaluation was performed for the activity due to the frequency of the above mentioned components.
The change in testing frequency for the turbine stop valves and CIV s results in a probability of low trajectory missile damage that is well below the acceptance criteria of lxl 0-6 per year and a probability of high trajectory missile damage on any safety related structure that is below the acceptance criteria of lxl 0-7 per year. The increase in the probability of a failure of a turbine control valve is increased by approximately 86% and the probability of malfunction of a CIV is increased by approximately 99%, which is less than the factor of two cited in NEI 96-07, Revision 1, "Guidelines for 10 CFR 50.59 Implementation" as constituting the threshold for a "More the Minimal" increase. As stated in NEI 97-07 Section 5.3.2 Example 8 states that to require prior NRC approval, the malfunction would require a likelihood increase of more than a factor of2 on the component level:
The change in likelihood of occurrence of a malfunction is calculated in support of the evaluation and increases by more than a factor of two. Note: The factor of two should be applied at the component level.
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Therefore, the proposed change does not result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the UFSAR.
10 CFR 50.59 Evaluation 23-004 Summary Description and
Purpose:
I EC 298541, Containment Boundary Change To Include Embedded Liner Leak Chase System The procedure for conducting the containment Type A integrated leak rate test (ILRT)
(EX1803.001) is being revised to specify performing the test with the vent plugs installed. The liner weld joints within the leak chases are not exposed to containment pressure when the plugs are installed. The leak chase system, liner and liner welds provide an equivalent leakage barrier in place of the embedded liner and liner welds for those locations where the leak chase system exists.
Evaluation Summary:
- This evaluation shows that the leak chase system functioning as part of the containment liner pressure boundary does not result in the change of the frequency of occurrence of any accidents, a change in the likelihood of occurrence of malfunctions, an increase in the consequences of an accident, an increase in the consequences of a malfunction, an increase in the possibility of an accident of a different type than is already analyzed in the UFSAR, the introduction of the possibility for a malfunction of an SSC with a different result, or result in a design basis limit for a fission product barrier as described in the UFSAR being exceeded or altered.
Based on the evaluation performed in this document, the leak chase system provides defense-in-depth redundancy against leakage when the plugs are installed. Removal of leak chase plugs exposes the inaccessible portion of the embedded liner to the containment atmosphere. Visual examinations that have been performed do not indicate significant degradation of the liner, consistent with the observed high pH of the water found within the leak chase system. Leak-tight integrity for exposed portions of the embedded liner is assured through reliance upon the liner design basis construction in accordance with ASME Section III, Division 2, Subsection cc.
Therefore, NRC approval is not required to implement this change.
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Seabrook Station 10 CFR 50.59 Report, Enclosure 2 to L-2023-152 Listing ofUFSAR Change Requests (UFCRs/UCRs) Incorporated in Updated Final Safety Analysis Report, Revision 22
Seabrook Station 10 CFR 50.59 Report, Enclosure 2 UFCR/UCR Number EC 297206 EC 297536 EC 290428 EC 293571 EC 296102 EC 297153 EC 297462 EC 297568 EC 297711 EC 298294 EC 298541 Affected Sections 3.5
' '4.2 8.2; 8.2.2; 8.2.3; 8.2.4 9.4.12.2 8.2.1.4.a.l; 8.2.1.4.a.3 8.3.1.1.d 6.2.1.1.a 3.8; 18.2 3.9(B).6 2.2.1.1; 2.2.2.2 3.8.1.1; 6.2.1.1.b.l Affected Tables 3.5-9; 3.5-10 8.3-1, 8.3-2 2.2-1 6.2-91 Page 1 of 1 Affected Figures 4.2-2a; 4.2-2b; 4.2-2c Figure 2.2-1; 2.2-5
Seabrook Station 10CFRS0.59 Report, Enclosure 3 to L-2023-152 Listing of UFSAR Change Requests (UFCRs) Incorporated in Fire Protection Safe Shutdown Capability (10CFR50, Appendix R), Revision 19
Seabrook Station 1 0CFRS0.59 Report, Enclosure 3 UFCR/UCR Number EC297539 EC296106 Affected Sections 3.2 3.2; 3.4 Affected Tables/ Tabulations Affected Figures Page 1 of 1
Seabrook Station 10CFR50.59 Report, Enclosure 4 to L-2023-152 Listing ofUFSAR Change Requests (UFCRs) Incorporated in Evaluation and Comparison to BTP APCSB 9.5-1,AppendixARevision 20
Seabrook Station 10CFRS0.59 Report, Enclosure 4 UFCR/UCR Number EC297539 Affected Sections F.2 Tab 2; F.2 Tab 11 Affected Tables Page 1 of 1 Affected Figures
Seabrook Station 10CFR50.59 Report, Enclosure 5 to L-2023-152 Listing of UFSAR Change Requests (UFCRs) Incorporated in Revisions 166 through 168 of the Technical Requirements Manual
Seabrook Station 10CFR50.59 Report, Enclosure 5 UFCR/UCR Number EC 297206 EC 297536 EC 297906 Affected Sections TR-23 6
TR-28 Page 1 of 1 Affected Tables Affected Figures TR 28-4.1
Seabrook Station 10CFRS0.59 Report, Enclosure 6 to L-2023-152 10 CFR 54.37(b)
Aging Management Review Summary
Seabrook Station 10CFRS0.59 Report, Enclosure 6 10 CFR 54.37(b) states that "After the renewed license is issued, the FSAR update required by 10 CFR 50.71(e) must include any systems, structures, and components newly identified that would have been subject to an aging management review or evaluation of time-limited aging analysis in accordance with §54.21. This FSAR update must describe how the effects of aging will be managed such that the intended function(s) in §54.4(b) will be effectively maintained during the period of extended operation."
This summary comprises of a period from 1/1/2022 through 6/30/2023 to align with the FSAR update as required within 10 CFR 50.71(e). In addition, this summary includes a review of engineering changes completed in the time period of 1/1/2022 to 6/30/2023.
During this reporting period, there was a new component identified to be added to the Aging Management Program for Seabrook Station identified within EC29814 7. In addition, there were replacement activities that would affect Aging Management Program for Seabrook Station identified within EC297777. Below describes the applicable Aging Management Programs that will be used to ensure the effects of aging will be managed such that the intended function(s) will be effectively maintained during the period of extended operation.
New stainless steel valve will be added to the Water Chemistry Aging Management Program LRAP-M002. Replacement interior tank coating will be added to the Fire Water System Aging Management Program LRAP-M027.
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Seabrook Station 10CFRS0.59 Report, Enclosure 7 to L-2023-152 Summary of Commitment Changes during the period of January 1st, 2022, through June 30th, 2023.
Seabrook Station 10CFRS0.59 Report, Enclosure 7 There were no changes made to Commitments during the period of January 1st, 2022, through June 30th, 2023 Page 1 of 1