SBK-L-07087, Revised No Significant Hazards Consideration Determination for License Amendment Request 06-03, Application for Amendment to the Technical Specifications for Miscellaneous Changes.
| ML071360401 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/14/2007 |
| From: | St.Pierre G Florida Power & Light Energy Seabrook |
| To: | Document Control Desk, NRC/NRR/ADRO |
| References | |
| SBK-L-07087, TAC MD2791 | |
| Download: ML071360401 (7) | |
Text
FPL Energy Seabrook Station FPL Energy P.O. Box 300 Seabrook, NH 03874 Seabrook Station (603) 773-7000 May 14, 2007 Docket No. 50-443 SBK-L-07087 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Seabrook Station Facility Operating License NPF-86 Revised No Significant Hazards Consideration Determination for License Amendment Request 06-03 "Application for Amendment to the Technical Specifications for Miscellaneous Changes"
References:
- 1. FPL Energy Seabrook, LLC letter SBK-L-06059, License Amendment Request 06-03, Application for Amendment to the Technical Specifications for Miscellaneous Changes, August 7, 2006.
- 2. NRC letter to FPL Energy Seabrook, LLC, Request for Additional Information Regarding License Amendment Request for Miscellaneous Technical Specification Changes (TAC NO.
MD 2791), November 22, 2006.
- 3. FPL Energy Seabrook, LLC letter SBK-L-06243, Response to Request for Additional Information Regarding License Amendment Request 06-03, Application for Amendment to the Technical Specifications for Miscellaneous Changes, January 22, 2007.
By letter dated August 7, 2006, (Reference 1) FPL Energy Seabrook, LLC submitted License Amendment Request (LAR) 06-03, Application for Amendment to the Technical Specifications for Miscellaneous Changes. In Reference 2, the NRC requested additional information in order to complete its evaluation of the LAR, and Reference 3 provided the requested information.
Subsequent discussions with the NRC staff regarding the submittal in Reference 3 identified a need to revise the No Significant Hazards Consideration Determination (NSHCD) for this LAR.
Therefore, this letter transmits a revision to the NSHCD previously submitted in Reference 3.
A oo an FPL Group company
United States Nuclear Regulatory Cornnission SBK-L-07087 / Page 2 This revised NSHCD does not alter the conclusion discussed in Reference 1 that the proposed changes do not involve a significant hazard consideration pursuant to 10 CFR 50.92. A copy of this letter has been forwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91(b).
Should you have any questions regarding this information, please contact Mr. James Peschel, Regulatory Programs Manager, at (603) 773-7194.
Very truly yours, FPL Energy Seabrook, LLC Gene St. Pierre Site Vice President Enclosure cc: S. J. Collins, NRC Region I Administrator G. E. Miller, NRC Project Manager, Project Directorate 1-2 W. J. Raymond, NRC Resident Inspector Mr. Christopher M. Pope, Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305
United States Nuclear Regulatory Commission SBK-L-07087 / Page 3 OATH AND AFFIRMATION I, Gene St. Pierre, Site Vice President of FPL Energy Seabrook, LLC, hereby affirm that the information and statements contained within this revised No Significant Hazards Consideration Determination for License Amendment Request 06-03 are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
Sworn and Subscribed before me this
/fi day of , 007 Gene St. Pierre Site Vice President 7' Public
Enclosure to SBK-L-07087 Revised No Significant Hazards Consideration Determination for License Amendment Request 06-03 "Application for Amendment to the, Technical Specifications for Miscellaneous Changes"
5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration
- 1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The probability or consequences of accidents previously evaluated in the UFSAR are unaffected by this proposed change. There is no change to any equipment response or accident mitigation scenario, and this change results in no additional challenges to fission product barrier integrity. The proposed change does not alter the design, configuration, operation, or function of any plant system, structure, or component.
As a result, the outcomes of previously evaluated accidents are unaffected.
This change limits availability of the charging pumps to one pump when in Mode 4 with the temperature of any RCS cold leg is less than or equal to 290 0F, in Mode 5, and in Mode 6 with the reactor vessel head on and the vessel head closure bolts not fully de-tensioned. Nonetheless, imposing this limitation does not alter the configuration or operation of the charging pumps from that specified in current administrative controls. Technical Specification (TS) 3/4.5.3, ECCS Subsystems -
Tavg Less Than 350'F, presently stipulates that only one charging pump is maintained operable in Mode 4. Similarly, Technical Requirement 26, Boration Systems, requires that all but one operable charging pump be demonstrated inoperable in Modes 4, 5, and 6. Also, the Seabrook Station Updated Final Safety Analysis Report (UFSAR) describes the configuration of the charging pumps during shutdown conditions: Prior to decreasing RCS temperature below 350°F, the safety injection pumps and the non-operating charging pumps are made inoperable.
Consequently, the change does not alter the configuration or operation of the charging pumps from the procedures presently described in the UFSAR; rather, it only relocates an existing limitation from the UFSAR to the technical specifications.
Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
This proposed change also revises the minimum water level in the service water system pump house required for operability of the service water system. The value currently specified in the technical specifications has been in error since 1986 and will be corrected with this change. Increasing the minimum required water level from five feet to 25.1 feet does not alter the configuration or operation of the service water system. Following discovery of this discrepancy, administrative controls established a minimum water level of approximately 25 feet. Moreover, monitoring of the service water pump house level during 2005 observed that the level, which is controlled by the ocean tides, is normally greater than 26 feet. During this period the minimum and maximum pump house water levels were 26.3 and 48.57 feet, respectively. This administrative change has no affect on the actual operation or configuration of the service water system. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed revision to TS Table 3.3-9, Remote Shutdown System, eliminates valves MS-V127 and MS-V128 from the table. Located in the main steam supply line to the turbine-driven emergency feedwater (TDEFW) pump, these are locked open, manually operated, valves. Supplement 4 of NUREG 0896, Safety Evaluation Report, discusses the modifications made to the Emergency Feedwater System (EFW) to address problems experienced with the EFW steam supply lines during hot functional testing. A design change, installed in 1991, changed MS-V127 and MS-V 128 to normally open valves, replaced the valves' pneumatic actuators with gear-operated manual operators, and re-assigned the EFW actuation and containment isolation functions of these valves to new automatic isolation valves (MS-V393 and MS-V394) in the TDEFW pump steam supply line. As a result, the elimination of MS-V127 and MS-V128 from TS Table 3.3-9 does not alter the design, configuration, operation, or function of these valves with regard to operation of the EFW system because in the existing design these normally open valves are not required to re-position to support operation of the TDEFW pump. Automatic valves MS-V393 and MS-V394, which actuate to initiate operation of the TDEFW pump, are appropriately under the control of TS Table 3.3-9. This proposed change does not alter the design, configuration, operation, or function of the EFW steam supply valves. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The other changes in this proposed amendment correct errors, remove an outdated license condition, remove an inconsistency between indexes, and revise a reporting requirement. These changes are administrative in nature and do not impact the design, configuration, operation, or function of any plant system, structure, or component.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
The proposed changes (1) relocate an existing limitation from the UFSAR to the technical specifications regarding availability of the charging pumps, (2) revise the minimum water level in the service water system pump house required for operability of the service water system, (3) eliminate valves MS-V127 and MS-V128 from TS Table 3.3-9, and (4) make administrative changes to the TS that correct errors, remove an outdated license condition and an inconsistency between indexes and revises a reporting requirement. No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed change. The proposed change does not challenge the performance or integrity of any safety-related system. The ability of any operable structure, system, or component to perform its designated safety function is unaffected by this change. The proposed change neither installs or removes any plant equipment, nor alters the design, physical configuration, or mode of operation of any plant structure, system, or component. No physical changes are being made to the plant, so no new accident causal mechanisms are being
ý I introduced. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. The proposedchanges do not involve a significantreduction in the margin ofsafety.
The margin of safety associated with the acceptance criteria of any accident is unchanged. The proposed change will have no affect on the availability, operability, or performance of safety-related systems and components. The proposed change relocates an existing limitation from the UFSAR to the technical specifications regarding availability of the charging pumps during operation in Mode 4 with the temperature of any RCS cold leg is less than or equal to 290'F, in Mode 5, and in Mode 6 with the reactor vessel head on and the vessel head closure bolts not fully de-tensioned. Nonetheless, imposing this limitation does not alter the configuration or operation of the charging pumps from those specified in current administrative controls and the UFSAR. The proposed change includes revising the minimum water level in the service water system pump house required for operability of the service water system. This change replaces a non-conservative, incorrect value in the TS with a minimum required water level that is consistent with the design basis for the system. The elimination of MS-V127 and MS-V128 from TS Table 3.3-9 does not alter the design, configuration, operation, or function of these valves with regard to operation of the EFW system because in the existing design these normally open valves are not required to re-position to support operation of the TDEFW pump.
Automatic valves MS-V393 and MS-V394, which actuate to initiate operation of the TDEFW pump, are appropriately under the control of TS Table 3.3-9. Last, the proposed amendment makes administrative changes to the TS that correct errors, remove an outdated license condition and an inconsistency between indexes and revises a reporting requirement.
The proposed changes do not alter the design, configuration, operation, or function of any plant system, structure, or component. The ability of any operable structure, system, or component to perform its designated safety function is unaffected by this change. Therefore, the margin of safety as defined in the TS is not reduced and the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, FPL Energy Seabrook concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92 (c), and accordingly, a finding of "no significant hazards consideration" is justified.