SBK-L-11130, License Amendment Request 11-03, Regarding Containment Spray Nozzles Surveillance Requirement

License Amendment Request 11-03, Regarding Containment Spray Nozzles Surveillance Requirement

ML11203A020
Person / Time
Site:	Seabrook
Issue date:	07/14/2011
From:	Freeman P Nextera Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-11130
Download: ML11203A020 (15)

Text

NEXTera ENERGY

',,0 ý EAROK July 14, 2011 10 CFR 50.90 SBK-L-1 1130 Docket No. 50-443 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station License Amendment Request 11-03 License Amendment Request Regarding Containment Spray Nozzles Surveillance Requirement 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) 11-03 for an amendment to the Technical Specifications (TS) for Seabrook Station. The proposed change replaces the ten-year surveillance frequency for testing the containment spray nozzles in accordance with TS surveillance 4.6.2.1 .d with an event-based frequency.

Attachment 1 to this letter provides NextEra's evaluation of the proposed change, and Attachment 2 provides a markup of the TS showing the proposed change. New TS pages with the proposed change incorporated will be provided when requested by the NRC Project Manager.

Associated TS Bases changes will be implemented in accordance with TS 6.7.6j, 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.

No new commitments are made as a result of this 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 11-03 with issuance of a license amendment by July 15, 2012 and implementation of the amendment within 90 days.

NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

United States Nuclear Regulatory Commission SBK-L-11130 / 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: 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 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

ENERY SEABROOK AFFIDAVIT SEABROOK STATION UNIT 1 Facility Operating License NPF-86 Docket No. 50-443 License Amendment Request 11-03 License'AmendmentRequest Regarding Containment Spray Nozzles Surveillance Requirement The following information is enclosed in support of this License Amendment Request:

S NextEra Energy Seabrook's Evaluation of the Proposed Change 0 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

• beforeme this 1 dayof 2011 K~*zzI~

Paul Freeman Notary Pblic Site Vice President

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

Subject:

License Amendment Request Regarding Containment Spray Nozzles Surveillance Requirement 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusion

6.0 REFERENCES

1

1.0

SUMMARY

DESCRIPTION The proposed change revises the Technical Specifications (TS) for the containment building spray (CBS) system. Current surveillance requirement (SR) 4.6.2.1 .d requires performing an air or smoke test through each containment spray header and verifying each spray nozzle is unobstructed at least once every ten years. NextEra proposes to replace the fixed ten-year interval with an event based frequency.

2.0 DETAILED DESCRIPTION The proposed change revises SR 4.6.2.1 .d as shown below:

d. At least once per-10 years by per-fomin an ai Or SMoke flow test through each spr.ay header-and verifing each spray nozzle is unobstr*eted. By verifying each spray nozzle is unobstructedfollowing activities that could result in nozzle blockage.

Attachment 2 provides the TS page marked to show the proposed change.

3.0 TECHNICAL EVALUATION

Background

Description of Containment Building Spray System [Reference 1]

The containment is maintained below design pressure following a primary or secondary system line rupture by the parallel action of the emergency core cooling system (ECCS) and the CBS system, which comprise the containment heat removal system discussed in the Seabrook Updated Final Safety Analysis Report. The CBS system is designed to remove the energy discharged to the containment following a loss of coolant accident or main steam line break to prevent the containment pressure from exceeding design pressure and to reduce and maintain containment temperature and pressure within acceptable limits. The ECCS system and CBS system are comprised of two identical trains, each train independent of the other and fully redundant. Failure of a single active component will not cause the loss of more than half of either system's 200 percent heat removal capacity.

The CBS system is comprised of the CBS pumps, heat exchangers, spray headers and nozzles, the refueling water storage tank (RWST), the spray additive tank (SAT), and the containment recirculation sumps along with the interconnecting piping and valves and associated instrumentation and controls. The CBS spray headers and nozzles are positioned in the containment dome to maximize coverage of the containment volume. Four separate headers (two for each train) are utilized to obtain distribution 2

of the flow. Each train contains 198 nozzles with each nozzle providing a design flow of 15.2 gallons per minute. The containment spray headers and nozzles are fabricated of Austenitic stainless steel.

The CBS system is actuated by a containment spray actuation signal, which is initiated by high pressure in the containment. The CBS system pumps deliver water from the RWST to the spray nozzles located high in the containment building.

Through out the injection phase, the CBS pumps deliver water from the RWST through the CBS heat exchangers to the spray nozzles in containment. A low-low level signal from the RWST initiates the recirculation mode of operation, and the suctions of the residual heat removal (RHR) and the CBS pumps automatically re-align to the containment recirculation sumps. Throughout the recirculation mode, the CBS pumps take suction from the water in the containment recirculation sumps and discharge through the CBS heat exchangers to the containment spray nozzles and into the containment.

Conditions the Proposed Change is Intended to Resolve This proposed change will eliminate unnecessary testing of spray nozzles by requiring the test be performed following activities or conditions that could potentially cause nozzle blockage. The current surveillance requires workers to verify air flow at each nozzle located at high elevations inside containment, and the proposed reduction in the frequency of testing will enhance personnel safety.

Additionally, the surveillance also requires the use of a compressor with high temperature output and the installation of high temperature hoses. Reduction in the use of the high temperature compressor and hoses would also enhance personnel safety. Similarly, the proposed change is expected to result in a reduction in personnel radiation exposure and outage costs associated with performing the test.

Evaluation The proposed change will allow testing for nozzle blockage based on the occurrence of activities that could cause nozzle blockage rather than a fixed periodic basis. This change is requested based on industry and plant experience that indicates blockage of the containment spray nozzles during normal plant operation is unlikely.

PerformanceHistory Preoperational testing of the CBS system verified the operational parameters of the spray pumps during recirculation to the RWST. This testing included a demonstration of the system response to engineered safety features signals and the ability of the sump to supply the CBS and RHR pumps. Flow testing of the nozzles 3

was performed by the manufacturer and was not performed in the field. An air flow test was performed to verify that no nozzles were plugged.

Periodic in-place air flow tests through the spray nozzles have been conducted at the interval specified in the TS. The air flow test is performed by removing a piping spool piece from the pipe riser to the ring header and connecting an external air source that supplies hot air (approximately 325 0 F) and verifying that each spray nozzle is not plugged using a thermography camera.

The containment spray nozzle test history is as follows:

" Test 1 Performed as part of preoperational test in 1986.

• Test 2 Performed on 8/21/1991 during refueling outage 1.

" Test 3 Performed on 5/12/2002 during refueling outage 8.

The results of each test demonstrated unobstructed flow through each nozzle. These tests confirmed that the systems were free from construction debris and that no debris that could have caused obstructions had entered the system following startup and operation of Seabrook Station.

Nozzle Blockage Mechanisms NUREG-1366, "Improvements to Technical Specifications Surveillance Requirements," [Reference 2] reported the results of an NRC staff review of industry experience related to problems with CBS systems. The report found that, in general, once the systems are tested after construction, they are not subject to blockage. The problems regarding nozzle blockage identified in the report were related to construction activities.

One postulated mechanism for blockage of spray nozzles is corrosion products. The containment spray headers and nozzles, however, are fabricated of Austenitic stainless steel. Therefore, blockage of the spray nozzles from corrosion products is unlikely.

Another mechanism for nozzle blockage is accumulation of solid boric acid in the spray lines or nozzles due to evaporated borated water. The CBS spray headers are normally maintained dry and isolated from water by normally closed containment isolation valves that are subject to Type C leakage testing. During refueling outages, the spray ring manual isolation valves are locked closed to ensure that inadvertent spray actuation cannot take place. As a further means to prevent materials from entering the system, the containment sumps may have covers installed.

Consequently, blockage of the CBS spray nozzles from solid boric acid accumulation 4

is unlikely. However, should there be inadvertent fluid flow though the nozzles, such as the result of spurious actuation, NextEra would evaluate testing and methods for verifying the nozzles are unobstructed.

ForeignMaterialExclusion (FME)

The FME program at Seabrook Station is governed by Fleet Procedure MA-AA-101-1000. This procedure ensures that appropriate precautions are taken to minimize inadvertent and uncontrolled introduction of foreign materials into plant systems and components. Breached fluid or piping systems shall be covered where possible except when the specific opening is attended or work, inspection, testing, sampling, or surveying is in progress that requires the removal of the FME cover. The procedure also includes FME practices for maintaining cleanliness of plant systems and components during maintenance activities that create debris, such as welding and grinding. Final cleanliness inspections verify the system, component, or process is free of foreign material prior to final closure.

NextEra's corrective action process is used in the event of a loss of FME integrity. If FME integrity is lost through the intrusion or discovery of foreign material, the procedure directs the worker to notify the work group supervisor or designee to develop a recovery plan for the foreign material. The recovery plan should include the following considerations: methods to save recovered materials for further analysis, determination of the source, location, and quantity of foreign material; determination of the need for additional inspections, and evaluation of possible equipment damage already caused or that may be caused by the foreign material.

NextEra performed a review of maintenance performed on the CBS system since the last containment spray nozzle test in refueling outage 8 in May 2002. The review identified one issue involving FME that impacted the CBS system. During installation of a new vent valve (CBS-V-178), the purge dam pipe became detached from the argon hose and fell into the piping. This issue was documented in the corrective action program; and in accordance with the FME program, a recovery plan was developed, the purge dam pipe was retrieved, and an internal FME inspection was performed. Identification of the FME issue, development of a recovery plan, and successful retrieval of the purge dam pipe indicate that NextEra has an effective FME program.

During other maintenance activities on the CBS system since the last containment spray nozzles test, work practices and post work inspections maintained system cleanliness. There have been no work activities on any of the containment spray nozzles or headers since the last containment spray nozzle test.

NextEra's administrative controls for FME ensure that foreign material is excluded from systems during maintenance activities, and these controls would be in place with 5

the CBS system open for maintenance. Therefore, the FME program provides reasonable assurance that debris or foreign matter that could adversely affect the CBS system's ability to perform its safety function would not be left in the system as a result of maintenance activities.

Conclusion The NRC has recognized that CBS nozzle testing on a ten-year frequency is unnecessary. NUREG-1366 found that problems in pressurized water reactor CBS systems were generally related to construction activities. Previously performed surveillance tests all found the Seabrook Station CBS nozzles unobstructed, and a reduced frequency of testing is justified when experience has shown routine testing at a specified frequency produces acceptable results. The design of the CBS system, maintenance and testing history of the system, and robust FME controls provide reasonable assurance that the reduced surveillance frequency will not impact the ability of the CBS system to perform its specified function.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 0 10 CFR 50.36, Technical Specifications, states (c) Technical specifications will include items in the following categories:

(3) Surveillance requirements.Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

• General Design Criterion 38--Containmentheat removal. A system to remove heat from the reactor containment shall be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.

• GeneralDesign Criterion39--Inspection of containment heat removal system. The containment heat removal system shall be designed to permit appropriate periodic inspection of important components, such as the torus, sumps, spray nozzles, and piping to assure the integrity and capability of the system.

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Criterion 40--Testing of containment heat removal system. The containment heat removal system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole, and under conditions as close to the design as practical the performance of the full operational sequence that brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of the associated cooling water system.

The changes proposed in this request will continue to meet the above regulatory requirements.

4.2 Precedent The NRC staff has approved similar license amendments including:

• Catawba, McGuire, and Oconee Stations (August 24, 2010; ADAMS Accession No. ML100690007) [Reference 3]

• Prairie Island Units, 1 and 2 (November 6, 2008; ADAMS Accession No.ML082740226) [Reference 4]

" Millstone Power Station, Unit 2 (March 31, 2008; ADAMS Accession No. ML080720304) [Reference 5]

" Arkansas Nuclear One Unit 1 (July 9, 2008; ADAMS Accession No. ML081540218) [Reference 6]

4.3 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 proposed change does not involve a significant increase in the probabilityor consequences of an accidentpreviously evaluated.

7

The spray nozzles and the associated containment spray system (CBS) are designed to perform accident mitigation functions. The proposed change to reduce the frequency and remove specific details of surveillance testing that verifies the spray nozzles are unobstructed 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.

The capability of the CBS system to perform its accident mitigation functions is not adversely affected by the proposed change.

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 change does not make any physical modifications to the CBS system, changes to setpoints, or changes to the method of delivering borated water to the CBS spray nozzles. The proposed change will not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis.

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 change does 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 8

adversely affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condition.

Therefore, the proposed change does 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 of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets 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.

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6.0 REFERENCES

1. Seabrook Station UFSAR, Revision 14, section 6.2.2

2. NUREG-1366, "Improvements to Technical Specifications Surveillance Requirements," December, 1992

3. NRC letter "Catawba Nuclear Station, Units 1 and 2, McGuire Nuclear Station, Units 1 and 2, and Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments Regarding Performance Testing of Containment Spray Nozzles (TAC Nos. ME2497, ME 2498, ME2499, ME2500, ME2501, ME2502 and ME2503)," August 24, 2010, ADAMS Accession ML100690007

4. NRC letter "Prairie Island Nuclear Generating Plant, Units I and 2 - Issuance of Amendments Re: License Amendment to Revise Containment Spray Nozzle Surveillance Requirements (TAC Nos. MD7362 and MD7363)," November 6, 2008, ADAMS Accession ML082740226

5. NRC letter "Millstone Power Station, Unit 2 - Issuance of Amendment Re:

Technical Specification Change Request Regarding Containment Spray Nozzle Test Requirements (TAC No. MD4992)," March 31, 2008, ADAMS Accession 080720301

6. NRC letter "Arkansas Nuclear One, Unit 1 - Issuance of Amendment Re:

Containment Spray Nozzle Technical Specifications Test Requirements (TAC No. MD83 10)," July 9, 2008, ADAMS Accession ML081540218 10

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

The attached markup reflects 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. 125.

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 LAR 10-02 Application for Change to the SBK-L-10074 05/14/2010 Technical Specifications for the Containment Enclosure Emergency Air Cleanup System LAR 10-04 Amendment to the Facility SBK-L-101 19 07/26/2010 Operating License and Submittal of the Seabrook Station Cyber Security Plan LAR 10-05 Application to Delete Technical SBK-L-10153 12/29/2010 Specification 3/4.4.10, Structural Integrity.

Application to Revise the Technical SBK-L-1 1066 04/21/2011 LAR 11-01 Specifications for Reactor Coolant Leakage Detection Instrumentation The following TS page is included in the attached markup:

Technical Title Page Specification TS 3.6.2.1 Containment Spray System 3/4 6-14 I

CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.1 Two independent Containment Spray Systems shall be OPERABLE with each Spray System capable of taking suction from the RWST* and automatically transferring suction to the containment sump.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With one Containment Spray System inoperable, restore the inoperable Spray System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 />; restore the inoperable Spray System to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be 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 />.

SURVEILLANCE REQUIREMENTS 4.6.2.1 Each Containment Spray System shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position is in its correct position;

b. By verifying OPERABILITY of each pump when tested pursuant to Specification 4.0.5;

c. At least once per 18 months during shutdown, by:

1) Verifying that each automatic valve in the flow path actuates to its correct position on a Containment Pressure-Hi-3 test signal, and

2) Verifying that each spray pump starts automatically on a Containment Pressure-Hi-3 test signal.

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• In MCDE 4, when the Residual Heat Removal System is in operation, ann'oa OPERABLE ow ctERABLugEnIflow path i one that is capable of taking suction from the refueling water storage s Ptank 0 ta n k upon up being manually realigned.

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