SBK-L-08007, Response to Request for Additional Information Re License Amendment Request (LAR) 07-02, Application to Revise the Technical Specifications Regarding Control Room Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidat

Response to Request for Additional Information Re License Amendment Request (LAR) 07-02, Application to Revise the Technical Specifications Regarding Control Room Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated.

ML080530391
Person / Time
Site:	Seabrook
Issue date:	02/19/2008
From:	St.Pierre G Florida Power & Light Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 07-002, SBK-L-08007, TSTF-448, Rev 3
Download: ML080530391 (11)

Text

0FPL FPL Energy Energy Seabrook Station P.O. Box 300 Seabrook, NH 03874 Seabrook Station (603) 773-7000 February 19, 2008 SBK-L-08007 Docket No. 50-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Response to Request for Additional Information Regarding License Amendment Request (LAR) 07-02, Application to Revise the Technical Specifications Regarding Control Room Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

References:

1. FPL Energy Seabrook, LLC letter SBK-L-07112, Application to Revise the Technical Specifications Regarding Control Room Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process, July 17, 2007.

2. FPL Energy Seabrook, LLC letter SBK-L-07142, Correction to License Amendment Request (LAR) 07-02, Application to Revise the Technical Specifications Regarding Control Room Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process, October 15, 2007.

3. NRC Request for Additional Information Regarding Proposed License Amendment Control Room Habitability, January 2, 2008.

In reference 1, FPL Energy Seabrook, LLC submitted a request for an amendment to the technical specifications (TS) for Seabrook Station. The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3. In Reference 3, the NRC requested additional information in order to complete its review of the LAR.

AcS an FPL Group company

United States Nuclear Regulatory Commission SBK-L-8007 / Page 2 contains FPL Energy Seabrook, LLC's response to the request for additional information. Attachment 2 provides replacement mark-up pages that reflect the changes to TS 3.7.6, TS 6.7.6.1, and the TS bases that result from the response to this request for information.

These pages supersede their corresponding pages in Reference 1. The bases changes associated with this LAR will be incorporated in accordance with the TS Bases Control Program.

The changes do not alter the conclusion in Reference I that the proposed change does 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). The Station Operation Review Committee has reviewed the changes to the proposed LAR.

Should you have any questions regarding this letter, please contact Mr. James M. Peschel, Regulatory Programs Manager, at (603) 773-7194.

Very truly yours, FPL Energy Seabrook, LLC.

Gene St. Pierre Site Vice President Attachments (2) cc: S. J. Collins, NRC Region I Administrator G. E. Miller, NRC Project Manager, Project Directorate 1-2 W. J. Raymond, NRC Senior 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

FPL nergy Seabrook Station AFFIDAVIT I, Gene F. St. Pierre, Site Vice President of FPL Energy Seabrook, LLC hereby affirm that the information and statements contained within this response to request for additional information regarding License Amendment Request 07-02 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 J!j dayof . 5-'u,

,2008 Gene St. Pierre Site Vice President

Attachment 1 FPL Energy, LLC Response to Request for Additional Information Regarding License Amendment Request (LAR) 07-02, Application to Revise the Technical Specifications Regarding Control Room Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

Request for Additional Infornmation:

1. For Plants that do not currently have any identified chemical hazards, the required action wording in TSTF-448 to verify that chemical hazards do not exceed limits could be satisfied if chemical hazard surveys are current per the licensee's programs. The required action wording in the model application, by including a chemical hazard assessment, also prevents a non-conservative technical specification in the event that a new chemical hazard is identified during a periodic survey.

For conditions when the Control Room Envelope (CRE) boundary is inoperable:

1. Provide justification for not assuring that chemical hazard surveys are current as part of the assessment in your proposed TS action 3.7.6.l.b.2

2. Describe the controls in place that would ensure TS 3.7.6.1.b.2 would be commensurately updated in the event that new chemical hazards are identified.

Response

FPL Energy Seabrook proposes to revise required action 3.7.6.1.b.2 to address chemical hazards consistent with TSTF-448, Revision 3. In addition, the proposed TS bases will be modified to discuss the action necessary to meet TS action 3.7.6.1.2.b with regard to chemical hazards. In the absence of chemical hazards, the action can be met by verifying that the chemical hazards analyses are current and require no toxic protection for the CRE occupants.

The proposed changes will prevent having a non-conservative TS and avoid the need for a TS change in the event a new chemical hazard is identified during a future offsite or onsite chemical hazards analysis. For this reason, proposed TS 6.7.6.1 will also be revised consistent with TSTF-448 to include chemical hazards in the scope of the Control Room Envelope Habitability Program. The requirement that Unfiltered air inleakage limitsfor hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within assumptions in the licensing basis will be satisfied, in the absence of identified chemical hazards, by the offsite and onsite chemical hazards analyses that conclude toxic protection for the CRE occupants is not required.

Attachment 2 Revised TS and Bases Page Mark-ups

INSERT NOTE

---

---------------- NOTE----------------------------

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

INSERT 1

a. With one CREMAFS train inoperable for reasons other than an inoperable CRE

boundary, INSERT 2

b. With one or both CREMAFS trains inoperable due to an inoperable CRE boundary:

1. Immediately initiate action to implement mitigating actions 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 />, and

2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits 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 />, and

3. Within 90 days, restore CRE boundary to OPERABLE status 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 />.

c. With two CREMAFS trains inoperable for reasons other than an inoperable CRE boundary, immediately enter Technical Specification 3.0.3.

INSERT 3

f. With one or both CREMAFS trains inoperable due to an inoperable CRE boundary, immediately suspend movement of irradiated fuel assemblies.

Retype of ProposedTS 3.7.6.1 (LCO and Actions only)

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM SUBSYSTEM EMERGENCY MAKEUP AIR AND FILTRATION LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent Control Room Emergency Makeup Air and Filtration System (CREMAFS) trains shall be OPERABLE.

APPLICABILITY: All MODES During movement of irradiated fuel assemblies

---

NOTE -------------------------

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

ACTION:

In MODE 1, 2, 3 or 4:

a. With one CREMAFS train inoperable for reasons other than an inoperable CRE boundary, 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 />.

b. With one or both CREMAFS trains inoperable due to an inoperable CRE boundary:

1. Immediately initiate action to implement mitigating actions 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 />, and

2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits 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 />, and

3. Within 90 days, restore CRE boundary to OPERABLE status 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 />.

INSERT 4

1. Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Makeup Air and Filtration System (CREMAFS),

CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.

b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

c. Requirements for (i) determining the unfiltered air in-leakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C. 1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C. 1 and C.2 of Regulatory Guide 1.197, Revision 0.

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREMAFS, operating at a flow rate of less than or equal to 600 CFM at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.

e. The quantitative limits on unfiltered air in-leakage into the CRE.

These limits shall be stated in a manner to allow direct comparison to the unfiltered air in-leakage measured by the testing described in paragraph c. The unfiltered air in-leakage limit for radiological challenges is the in-leakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE

occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered in-leakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, and during movement of irradiated fuel assemblies, the CREMAFS must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

During movement of irradiated fuel assemblies, the CREMAFS must be OPERABLE to cope with the release from a fuel handling accident.

ACTIONS a.

When one CREMAFS train is inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREMAFS train is adequate to perform the CRE occupant protection function. However, the overall reliability is reduced because a failure in the OPERABLE CREMAFS train could result in loss of CREMAFS function.

The 7-day Completion Time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train to provide the required capability.

b.1, b.2, and b.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE),

or inadequate protection of CRE occupants from smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. A survey of offsite and onsite chemicals identified no hazardous chemicals that present a hazard to control room habitability. Therefore, the mitigqatinq action for chemical hazards is to verify that the chemical hazards analyses are current and require no toxic protection for the CRE occupants. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions.

The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90-day Completion Time is a 4