SBK-L-10097, License Amendment Request 10-03

License Amendment Request 10-03

ML101870104
Person / Time
Site:	Seabrook
Issue date:	06/28/2010
From:	Freeman P NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 10-03, SBK-L-10097
Download: ML101870104 (16)

Text

NEXTera m ENERQY SEABROOK 10 CFR 50.90 SARO June 28, 2010 SBK-L-10097 Docket No. 50-443 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station License Amendment Request 10-03 Relocation of Technical Specification 3.8.4.2, Containment Penetration Conductor Overcurrent Protective Devices and Protective Devices for Class 1E Power Sources Connected To Non-Class lE Circuits In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), NextEra Energy Seabrook, LLC (NextEra) is submitting License Amendment Request (LAR) 10-03 for an amendment to the Technical Specifications (TS) for Seabrook Station. The proposed change would revise TS 3.8.4.2, Containment Penetration Conductor Overcurrent Protective Devices and Protective Devices for Class lE power Sources Connected to Non-Class lE Circuits, by relocating the requirements in TS 3.8.4.2 to the Technical Requirements Manual (TRM).

Attachment 1 to this letter provides NextEra's evaluation of the change, and Attachment 2 provides a markup of the TS showing the proposed change. The TS bases information related to TS 3.8.4.2 will be relocated to the TRM in accordance with TS 6.7.6.j, TS Bases Control Program, upon implementation of the license amendment. As discussed in the evaluation, the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change.

The Station Operation Review Committee has reviewed this LAR. A copy of this LAR has been forwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91(b).

NextEra requests NRC review and approval of LAR 10-03 with issuance of a license amendment by March 30, 2011 and implementation of the amendment within 30 days. This schedule will support work activities planned for the spring 2011 refueling outage.

/4oou(ULe NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

United States Nuclear Regulatory Commission SBK-L-10097 / Page 2 Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.

Sincerely, NextEra Energy Seabrook, LLC Paul Freeman Site Vice President Attachments

1. NextEra Energy Seabrook's Evaluation of the Proposed Change

2. Markup of the Technical Specifications cc: S. J. Collins, NRC Region I Administrator G. E. Miller, NRC Project Manager 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 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

ENER(QY

- SEABROOK AFFIDAVIT The following information is enclosed in support of this License Amendment Request:

0 NextEra Energy Seabrook's Evaluation of the Proposed Change S Markup of the Technical Specifications I, Paul Freeman, Site Vice President of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within this license amendment request 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 Z*2j=4", day of -e ,2010 Paul Freeman Site Vice President

Attachment 1 NextEra Energy Seabrook's Evaluation of the Proposed Change

Subject:

Relocation of Technical Specification 3.8.4.2, Containment Penetration Conductor Overcurrent Protective Devices and Protective Devices for Class 1E Power Sources Connected to Non-Class 1E Circuits 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusion

6.0 REFERENCES

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1.0

SUMMARY

DESCRIPTION The proposed change relocates Technical Specification (TS) 3.8.4.2, Containment Penetration Conductor Overcurrent Protective Devices and Protective Devices for Class 1E Power Sources Connected to Non-Class lE Circuits, to the Seabrook Station Technical Requirements Manual (TRM).

2.0 DETAILED DESCRIPTION The proposed change deletes TS 3.8.4.2, Containment Penetration Conductor Overcurrent Protective Devices and Protective Devices for Class lE Power Sources Connected to Non-Class 1E Circuits, from the TS and relocates the requirements of TS 3.8.4.2:to the TRM. The TS Index is also revised to reflect this change.

3.0 TECHNICAL EVALUATION

Background

Criteriafor Technical Specifications Section 50.36c(2)(ii) of Title 10 of the Code of Federal Regulations (10 CFR 50.36c(2)(ii)) contains the requirements for items that must be in TS. This regulation provides four criteria that can be used to determine the requirements that must be included in the TS. A TS limiting condition for operation (LCO) of a nuclear reactor must be established for each item meeting one or more of the following criteria:

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of, or presents a challenge to the integrity of a fission product barrier.

Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of, or presents a challenge to the integrity of a fission product barrier.

Criterion 4: A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

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Items not meeting any of these four criteria can be relocated from the TS to a licensee controlled document. Relocated requirements can then be changed, if necessary, in accordance with 10 CFR 50.59.

ElectricalProtective Devices TS 3.8.4.2 establishes the requirements for containment penetration overcurrent protective devices and protective devices for Class 1E power sources connected to non-Class 1E circuits. The containment penetration protective devices protect penetration integrity in the event of an electrical fault. These protective devices ensure that long or short duration overcurrents, which are capable of damaging a penetration, will be interrupted before they cause damage.

The design of the Seabrook Station electrical system associates all of the non-Class 1E circuits with Class 1E circuits. Non-Class 1E circuits that are powered from Class lE sources have the potential to degrade a Class 1E circuit. Therefore, this type of associated circuit is provided with at least one protective device to prevent degradation of the Class 1E circuit. These protective devices are required to perform their current interrupting function to prevent failure of the associated circuit from degrading that Class lE circuit.

Evaluation Following is an evaluation of the proposed change with regard to the criteria of 10 CFR 50.36c(2)(ii).

Criterion 1 addresses installed instrumentation that is used to detect and indicate excessive reactor coolant system leakage. TS 3.8.4.2, which addresses containment penetration conductor overcurrent protective devices and protective devices for Class 1E power sources connected to non-Class 1E circuits, does not cover installed instrumentation that is used to detect, and indicate in the control room, a significant degradation of the reactor coolant pressure boundary. Thus, the containment penetration conductor overcurrent devices and protective devices for Class 1E power sources connected to non-Class 1E circuits do not satisfy Criterion 1.

The purpose of Criterion 2 is to capture those process variables that have initial values assumed in the design basis accident and transient analyses and that are monitored and controlled during power operation. This criterion also includes active design features (e.g., high-pressure/low-pressure system valves and interlocks) and operating restrictions (pressure/temperature limits) needed to preclude unanalyzed accidents and transients. The electrical protective devices do help preserve the assumptions of the accident analysis by enhancing proper equipment operation. However, they are not a process variable, design 3

feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. Therefore, the containment penetration conductor overcurrent devices and protective devices for Class lE power sources connected to non-Class 1E circuits do not satisfy Criterion 2.

The purpose of Criterion 3 is to capture only those structures, systems, and components that are part of the primary success path of the safety analysis (the actions required to mitigate the consequences of the design basis accidents and transients). The primary success path of a safety analysis consists of the combinations and sequences of equipment needed to operate so that the plant responses to the design basis accident and the transients limit the consequences of these events within the appropriate acceptance criteria. Also captured by this criterion are those support and actuation systems that are necessary in the primary success path, but this criterion does not include backup and diverse equipment. The penetration conductor overcurrent protective devices are installed to minimize the damage from a fault in a component inside containment or in conductors that penetrate containment. The protective devices for Class lE power sources prevent failure of a non-Class 1E circuit from degrading a Class 1E circuit. Although these devices enhance equipment operation, they are not a structure, system, or component that is part of the primary success path whose function or actuation mitigates a design bases accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. Consequently, the containment penetration conductor overcurrent devices and protective devices for Class 1E power sources connected to non-Class lE circuits do not satisfy Criterion 3.

The purpose of Criterion 4 is to capture only those structures, systems, and components that operating experience and probabilistic safety assessment has shown to be significant to the public health and safety. The electrical protective devices are not a structure, system, or component that operating experience or probabilistic safety assessment has shown to be significant to the public health and safety. The electrical protective devices are not risk-significant and the Maintenance Rule (10 CFR 50.65) does not require these protective devices to be monitored for unavailability. Therefore, the containment penetration conductor overcurrent devices and protective devices for Class 1E power sources connected to non-Class 1E circuits do not satisfy Criterion 4.

Precedent In response to the Commission's Interim Policy Statement on Technical Specification Improvements, published in February 1987, the nuclear steam supply system owners groups submitted for NRC review a report that proposed relocating certain TS (Split Report). Following a review of the reports, the NRC staff published its conclusion in May 1988 [Reference 1], which concurred with the proposal that the TS for containment penetration conductor overcurrent protective devices may be relocated from the TS.

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NUREG-1431, Standard Technical Specifications Westinghouse Plants [Reference 2],

does not include a LCO for containment penetration conductor overcurrent protective devices. As discussed previously, during development of NUREG 1431, these devices were determined not to meet the criteria of 10 CFR 50.36c(2)(ii) for inclusion in the TS.

The NRC previously approved similar requests to relocate the TS requirement for containment penetration conductor overcurrent protective devices. Amendment 192 to the Millstone Nuclear Power Station Unit 3 TS, issued in January 2001 [Reference 3]

approved relocation of TS 3.8.4.1, Containment Penetration Conductor Overcurrent Protective Devices, to the TRM. Similarly, Arkansas Nuclear One Unit 2 received amendment 263 in January 2006 [Reference 4], which approved relocation of TS 3.8.2.5, Containment Penetration Conductor Overcurrent Protective Devices Conclusion The proposed change would relocate TS 3.8.4.2, Containment Penetration Conductor Overcurrent Protective Devices and Protective Devices for Class 1E Power Sources Connected to Non-Class lE Circuits, to the TRM. The requirements in this TS do not meet any of the criteria in 10 CFR 50.36c(2)(ii) for items that must be retained in the TS.

In addition, Section 3.8, Electrical Power Systems, of NUREG-1431 does not contain an LCO for containment penetration conductor overcurrent protective devices. The TS bases information related to TS 3.8.4.2 would also be relocated to the TRM in accordance with the TS Bases Control Program.

The Seabrook Station UFSAR [Reference 5] discusses the protective devices for containment penetrations and Class lE power sources. Relocation of the TS addressing these protective devices will not change the plant design and licensing basis or compliance with the UFSAR discussion of these protective devices.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36c(2)(ii) contains the criteria for items that must be included in the TS. The requirements in TS 3.8.4.2 do not meet any of the criteria for inclusion in the TS; therefore, NextEra concludes that relocation of TS 3.8.4.2 is acceptable.

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4.2 Significant Hazards Consideration No Significant Hazards Consideration In accordance with 10 CFR 50.92, NextEra Energy Seabrook has concluded that the proposed change does not involve a significant hazards consideration (SHC).

The basis for the conclusion that the proposed change does not involve a SHC is as follows:

1. The proposedchange does not involve a significant increase in the probability or consequences of an accidentpreviously evaluated.

The proposed change does not impact the physical function of plant structures, systems, or components (SSCs) or the manner in which SSCs perform their design function. The proposed change neither adversely affects accident initiators or precursors, nor alters design assumptions. The proposed change does not alter or prevent the ability of operable SSCs to perform their intended function to mitigate the consequences of an initiating event within assumed acceptance limits.

This proposed change relocates the requirements for the containment penetration conductor overcurrent protective devices and the protective devices for Class 1E power sources connected to non-Class 1E circuits to the TRM. Relocating these requirements will have no adverse effect on plant operation, the availability or operation of any accident mitigation equipment, or plant response to a design basis accident. The electrical protective devices are not accident initiators. Whether the requirements for penetration protective devices and protective devices for 1E power sources are contained in the TS or the TRM has no effect on the probability or consequences of any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of accidentfrom any previously evaluated.

The proposed change will not impact the accident analysis. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a significant change in the method of plant operation, or new operator actions. The proposed change will not introduce failure modes that could result in a new accident. The change does not alter assumptions made in the safety analysis.

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Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed changes do not involve a significant reduction in the margin of safety.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public.

The proposed change does not involve a significant change in the method of plant operation, and no accident analyses will be affected by the proposed changes. Additionally, the proposed changes will not relax any criteria used to establish safety limits and will not relax any safety system settings. The safety analysis acceptance criteria are not affected by this change. The proposed change will not result in plant operation in a configuration outside the design basis. The proposed change does not adversely affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condition.

Therefore, these proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, NextEra concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(b), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

NextEra has evaluated the proposed amendment for environmental considerations. The review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts 7

of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set for in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NRC letter from T. Murley to W. Wilgus, "NRC Staff Review of Nuclear Steam Supply System Vendor Owners Groups' Application of the Commission's Interim Policy Statement Criteria to Standard Technical Specifications," May 9, 1988

2. NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 3

3. NRC letter "Millstone Nuclear Power Station, Unit No. 3 - Issuance of Amendment Re: Relocation of Selected Technical Specifications Related to Instrumentation (TAC NO. MA8747)," January 16, 2001 (ADAMS Ascension No. ML003775927)

4. NRC Letter "Arkansas Nuclear One, Unit No. 2 - Issuance of Amendment Re:

Technical Specification Change Request for Electrical Equipment Protective Devices (TAC NO. MC5782)," January 23, 2006 (ADAMS Ascension No. ML052910484)

5. Seabrook Station UFSAR sections 8.3.1.1 and 8.3.1.4, Revision 113.

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Attachment 2 Mark-up of the Technical Specifications (TS)

The attached markups reflect the currently issued version of the TS and Facility Operating License. At the time of submittal, the Facility Operating License was revised through Amendment No. 123.

Listed below are the license amendment requests that are awaiting NRC approval and may impact the currently issued version of the Facility Operating License affected by this LAR.

LAR -Title NextEra Energy, Date Seabrook Letter" Submitted' Revision to Technical Specification SBK-L-09118 05/28/2009 LAR 09-03 6.7.6.k, "Steam Generator (SG)

Program," for Permanent Alternate Repair Criteria (H*)

LAR 09-04 Amendment to the Facility SBK-L-09218 11/19/2009 Operating License and Submittal of the Seabrook Station Cyber Security Plan LAR 10-01 Operations Manager Qualification SBK-L-10010 03/16/2010 Requirements LAR 10-02 Application for Change to the SBK-L-10074 05/14/2010 Technical Specifications for the Containment Enclosure Emergency Air Cleanup System The following TS pages are included in the attached markup:

Technical, Page Specification Title TS Index viii TS 3.8.4.2 Containment Penetration Conductor Overcurrent Protective 3/4 8-21 Devices and Protective Devices for Class IE power 3/4 8-22 Sources Connected to Non-Class 1E Circuits 3/4 8-23

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.7.2 STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION ...... 3/4 7-11 3/4.7.3 PRIMARY COMPONENT COOLING WATER SYSTEM 3/4 7-12 3/4.7.4 SERVICE WATER SYSTEM / ULTIMATE HEAT SINK 3/4 7-13 3/4.7.5 (THIS SPECIFICATION NUMBER IS NOT USED) ............................................ 3/4 7-14 3/4.7.6 CONTROL ROOM SUBSYSTEM 3/4 7-16 Emergency Makeup Air and Filtration .................................................................. 3/4 7-16 A ir C onditioning ...................................................................................................... 3/4 7-18a 3/4.7.7 SNUBBERS............................................ 3/4 7-19 3/4.7.8 SEALED SOURCE CONTAMINATION 3/4 7-20 3/4.7.9 (THIS SPECIFICATION NUMBER IS NOT USED)............................................ 3/4 7-22 3/4.7.10 (THIS SPECIFICATION NUMBER IS NOT USED) ............................................ 3/4 7-23 TABLE 3.7-3, (THIS TABLE NUMBER IS NOT USED) .................................................. 3/4 7-24 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES O perating ................................................................................................................. 3/4 8-1 TABLE 4.8-1 (THIS TABLE NUMBER IS NOT USED)................................................ 3/4 8-10 Shutdown......................................... 3/4 8-11 3/4.8.2 D.C. SOURCES O perating ................................................................................................................. 3/4 8-12 TABLE 4.8-2 BATTERY SURVEILLANCE REQUIREMENTS...................................... 3/4 8-14 Shutdown ........................................... 3/48-15 3/4.8.3 ONSITE POWER DISTRIBUTION O perating ................................................................................................................. 3/4 8-16 Shutdown ................................................ 3/48-18 Trip Circuit for Inverter I-2A ................................................................................... 3/4 8-19 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES A.C. Circuits Inside Primary Containment ........................................................... 3/4 8-20 onta.arent Pe ion Cond r vercurrt Pro ve Device Protec evice fClass 1 wer Sour to Non-Cla 1 E Circui......... ............ .3/.-1 Motor-Operated Valves Thermal Overload Protection ................................. 3/4 8-24 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION .................................. 3/4 9-1 3/4 9.2 INSTRUMENTATION ....................................... 3/4 9-2 3/49.3 DECAY TIME 3/49-3 SEABROOK - UNIT 1 viii Amendment No. 5,* 3,6*

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3.8.4.2 ,E-lach containment pene rion conductor overcurrr nt protective devic nd each protecge device for Class 1 E er sources connecte o non-Class 1 E cir its shall be OP ABLE.

APPLICABILITY: M ES 1, 2, 3, 4, 5,* and ACTION:

a. h one or more of the c tainment penetr n conductor overc ent protective device(s) inoperable:

1) Restore protective devic ) to OPERABLE us or deenergize circuit by tripping the ad ated circuit br er or racking out emoving the operable protecti 'device wthin 72 urs, declare the cted system component mnop ble, and verify th circuit breaker to tripped or the inoperal pte yVe device to be r ed out or remov at least once per 7 days thereaft , or

2) Be in at ast HOT STAN within the next ours and in COLD SHU OWN within th Illowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />

b. With o or more of the ass 1E power so ce protective device(s operable, res e the prote~ctive evice(s) to OPE LE status or deener e the circuit(s) by ping the circIt eaker or racking t or removing the mno rable protective device within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, eclare the affect component inoperab I and verify the circuit breaker to be ipped or the mno rable protective devic o be racked out or remov at least per 7 days ther fter.

SURVEIL CEREQUIREM TS 4.8. Each contain ent penetration cond tor overcurrent and Cla 'IE power rce protective de* e shall be demonstr ed OPERABLE: r

a. At ast once per 18 mo s:: r

1) By verifying at the medium voltage .8-kV and 4.16-k circuit breakers re OPERABLE by select g, on a rotating b is, at least I one of e circuit breakers, and rforming the folio-ng:

SEABROOK - UNIT 1 3/4 8-21

ELECTRICAL POWER SYAEMS ELECTRICAL EQUIP NT PROTECTIVE D VICES CONTAINMENT P\ETRATION COND TOR OVERCURRE PROTE IVE DEVI S AND PROTECTI DEVICES NON-CLASS 1,E CIRCUITS FOR //,

CLASS lE POWER SOUIJCES CON ECTED TO SURVEILýANCE REQUIREME /S Z Z 4.8.4.1) (Continued)//

a) A CHANNEL CA RATION of e associat d protective relays (because of the arge current involved, it i impractical to inject primary side ignals to curr nt transform rs; therefore, the chaprel calibration ill be perfor d by injectin a signal on the seco0ary side of t se transfor rs at their te plug),

b) An in grated syste functional te which includes sim ated aut ati caccuati of the syste and verifying that e h relay and a sociated irc breakers an control circuits func t n as i/esigned, an c) For each c' cuit breaker f und inoperable durin these functional tests, on additional cir it breaker of the mno erable type shall also be fun ionally tested ntil no more failures re found or all circuit brea rs of that typ have been function y tested.

2) By select' g and functio ally testing a repres tative sample of at least 10%of chtype of lo er voltage circuit br kers and overload device Circui reakers and verload devices sel cted for functional testing all be lected on a r ating basis.

sting of air ci uit breakers shall c sist of injecting a current ith a alue equal to 00% of the pickup the long-time delay trip ement and 150% of the ickup of the short-tip e delay trip element.T instantan us element sha~ll obe tested by injecting a,currn equal to +/-20%

of the piup value of the ele ent.

Testi of thermal magneti molded-case circuit br akers shall consist of inj ting a current with a alue equal to 30%of e circuit breaker trip r ing and -2,5% to +40 6 of the circuit breaker

• stantaneous trip ran or Testing of combin on starters (a magnet' only molded-case ci uit breaker in series ith a motor starter an integral overload devye) shall consist of injecti g a current with a val e equal to -25% to + % of the circuit breaker sananeous tripseint, and 200% and 0% of the thermal overl ad device trip rating the respective devi s.

Circuit bre kers and/or overloa devices found inoper ble during function testing shall be rest red to OPERABLE s tus prior to resu ng operati n. For each circuit b aker and or overloa evices found nope ble during these fu ctional tests, an addi nal representativ sam le of at least 10% o all the circuit breaker and or overload evices of e inoperable type s all also be functionall tested until no re type have been functionally tested.

SEABROOK - UNIT 1 3/4 8-22 ale

SEABROOK - UNIT 1 3/4 8-23