ML25335A147
| ML25335A147 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/01/2025 |
| From: | V Sreenivas NRC/NRR/DORL/LPL1 |
| To: | Phillabaum J Nextera Energy |
| Sreenivas V, NRR/DORL/LPL1 | |
| References | |
| Download: ML25335A147 (0) | |
Text
From:
Dr V Sreenivas To:
Phillabaum, Jerry Cc:
Undine Shoop; Keith Miller; Jeffrey Herrera; Jessie Quichocho
Subject:
SEABROOK STATION, UNIT NO. 1: REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLAN Date:
Monday, December 1, 2025 12:47:00 PM By application dated May 12, 2025 (Agencywide Documents Access and Management System Accession No. ML25132A013), NextEra Energy Seabrook LLC (NextEra) requested U.S. Nuclear Regulatory Commission (Commission, NRC) review and approval of a proposed license amendment request (LAR) to revise the Seabrook Station, Unit No. 1 (Seabrook) Renewed Facility Operating License NPF-86, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Application for amendment of license, construction permit, or early site permit.
Specifically, the proposed LAR would revise Emergency Action Levels (EALs) for Initiating Condition (IC) HU4 in procedure ER 1.1,"Classification of Emergencies," for Seabrook.
The U.S. Nuclear Regulatory Commission (NRC) staff has completed its review of the submitted application and has determined that additional information is required to continue and complete the technical evaluation. Accordingly, the following request for additional information (RAI) is provided:
RAI No. 1
Requirement:
10 CFR 50.47(b)(4) requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Issue: The Detector Design section in enclosure section 3.0, Technical Evaluation states, in part:
Photoelectric detectors are less prone to false alarms than ionization type detectors because they require products of combustion to enter a photo chamber and re-direct a light beam. Small amounts of dust or humidity will not actuate an alarm because it would not be sufficient to re-direct the light beam but could provide a trouble condition on the fire alarm panel indicating that the detector is dirty and needs servicing.
, IC HU4 Basis Information, states in part:
It can be reasonably expected that a fire that burns for 15-minutes would produce sufficient products of combustion to cause 3 or more fire detectors to alarm. Actuation of 3 or more fire detectors is therefore more reliable than a single fire detector of a valid alarm.
Additionally, Attachment 2, IC HU4 Basis Information, states in part:
For valid alarms in containment (3 or more alarms within 15-minutes that do not reset), the presence of fire in containment must be disproved within 60-minutes from the initial alarm, or an Unusual Event declaration is warranted.
The Seabrook proposed HU4 EAL criteria for determining a valid alarm in containment was changed from being considered valid, upon receipt of multiple zones (more than 1) actuated on CP-376 panel to a valid alarm in containment consisting of 3 or more alarms within 15-minutes that do not reset. The license amendment request did not provide technical justification for why two (2) detectors in an alarm condition would not be considered a valid fire alarm and the need for a third detector to be in an alarm condition in order for the fire to be considered valid inside containment.
Additionally, the Seabrook proposed HU4 EAL removed the note that provided decision making criteria for the determination of a valid alarm in containment in the proposed HU4 EAL without a technical justification.
RAI 1.a: Provide the technical basis and associated justification for why 2 fire detectors in an alarm condition would not be considered a valid fire alarm inside containment and provide a technical justification as to why 3 fire detectors would be needed for the declaration of an unusual event for a fire inside containment.
RAI 1.b: Provide a revised HU4 EAL that contains the note with the criteria for the determination of a valid fire alarm inside containment or provide a technical justification on why the note was removed.
RAI No. 2
Requirement:
10 CFR 50.47(b)(4) requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Issue: Attachment 2, IC HU4 Basis Information, appears to be incomplete and is missing technical basis information for the proposed EALs HU4-1 and HU4-2. The current HU4 EAL technical basis contains the information as does NEI 99-01 Rev 7.
Request: Provide an updated basis with the requested information or provide technical justification for why this is no longer required.
RAI No. 3
Requirement:
10 CFR 50.47(b)(4) requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Issue: Attachment 1, EALs for IC HU4, the Notes: Section states:
For EAL #1, STED/SED should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
However, the note from NEI 99-01 Revision 7 states:
For EAL #1, the Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded or will likely be exceeded.
(emphasis added)
The proposed language is not consistent with NEI 99-01 Revision 7.
Request: Revise the proposed HU4 EAL to reflect the language in NEI 99-01 Revision 7 or provide technical justification for the proposed change.
A draft Request for Additional Information (RAI) was provided to the licensee on November 19, 2025, to support any necessary technical clarifications. Subsequently, a technical clarification call was held on December 1, 2025. The licensee is requested to submit a response by January 15, 2026 to support their 2026 spring outage. The NRC staff requests as part of the RAI submitted response that NextEra provide a clean version of the proposed EAL and associated technical basis.
If you have any questions, please feel free to contact me. Please note that a copy of this email will be made publicly available in ADAMS.
V.Sreenivas, Ph.D., CPM.,
Licensing Project Manager Seabrook, Beaver Valley and Ginna Nuclear Power Plants Dn. of Operating Reactors Licensing, LPL1 U.S. Nuclear Regulatory Commission V.Sreenivas@nrc.gov