SBK-L-12054, Response to Request for Additional Information Regarding License Amendment Request 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System

Response to Request for Additional Information Regarding License Amendment Request 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System

ML120790307
Person / Time
Site:	Seabrook
Issue date:	03/15/2012
From:	Freeman P NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 10-002, SBK-L-12054
Download: ML120790307 (22)

Text

NEXTeraM ENERG-7YN March 15, 2012 10 CFR 50.90 SBK-L-12054 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 10-02, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System"

References:

1. NextEra Energy Seabrook, LLC letter SBK-L- 10074, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System," May 14, 2010

2. NextEra Energy Seabrook, LLC letter SBK-L-10 143, Response to Request for Additional Information Regarding License Amendment Request (LAR) 10-02, "Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System," August 24, 2010

3. NextEra Energy Seabrook, LLC letter SBK-L-I 1184, Response to Request for Additional Information Regarding License Amendment Request 10-02, Regarding the Containment Enclosure Emergency Air Cleanup System, September 16, 2011

4. NRC letter "Seabrook Station Unit I - Request for Additional Information Regarding the Addition of Action Statement to Limiting Condition for Operation 3.6.5.1, "Containment Enclosure Emergency Air Cleanup System" (TAC No. ME3988)," February 22, 2012 NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874 P1 L ý

United States Nuclear Regulatory Commission SBK-L-12054 / Page 2 In Reference 1 and supplemented by References 2 and 3, NextEra Energy Seabrook, LLC (NextEra) submitted a request for an amendment to the Technical Specifications (TS) for Seabrook Station. The proposed amendment would add an action statement allowing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation with both trains of the containment enclosure building emergency air cleanup system inoperable due to an inoperable containment enclosure building. This change would align TS 3.6.5.1 with TS 3.6.5.2, which currently allows operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the containment enclosure building is inoperable.

In Reference 4, the NRC requested additional information in order to complete its review of the amendment request. The Enclosure to this letter contains NextEra's response to the request for additional information. Attachment I to the Enclosure provides revised markups of the TS showing the proposed changes, which replace the markups provided in Reference 2. Attachment 2 to the Enclosure contains revised TS Bases that replace the proposed Bases provided in Reference 2. The Bases are provided for information and will be implemented in accordance with TS 6.7.6.j, TS Bases Control Program, upon implementation of the license amendment.

The modification to the proposed change does 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).

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 Enclosure cc: NRC Region I Administrator J. G. Lamb, NRC Project Manager, Project Directorate 1-2 W. J. Raymond, NRC Senior Resident Inspector

United States Nuclear Regulatory Commission SBK-L-12054 / Page 3 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

FPL Ene guv Seabrook Station AFFIDAVIT SEABROOK STATION UNIT I

. Facility.Operating License NPF-86 Docket No.,50-443 Response to Request for-Additional InformationRegarding License Amendment Request.,

10-02, "Applicationwfor Change tothe:Technical Specifications for the Containmentý "Enclosure Emergency Air Cleanup System" I, Paul Freeman, Site Vice President of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within this response to request for additional information regarding License Amendment Request 10-02 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

/si.*' day of x2 -- ,2012

(;7ý !IZ-IL11,=

'4 Paul Freeman

/ - - -Notary/ublic Site Vice President

Enclosure Response to Request for Additional Information (RAI)

Question 1 By letter dated September 16, 2011 (Agencywide Document Access and Management System (ADAMS) Accession No. ML11266A041), NextEra Energy Seabrook (Seabrook), LLC (licensee) submitted "Response to Request for Additional Information Regarding License Amendment Request 10-02, Regarding the Containment Enclosure Emergency Air Cleanup System:" The NRC staff request for additional information stated:

Given the differences in format and content between NUREG- 1431 and Seabrook TS, please describe how the proposed TS change provides an equivalent level of safety compared to that found in NUREG- 1431.

The NRC staff received a response to its request that compared the Seabrook containment design function to the containment design function in NUREG-143 1, Standard Technical Specifications Westinghouse Plants (STS). The response concluded that the Seabrook's Containment Enclosure Building Integrity (TS 3.6.5.3) is similar to the STS Shield Building (TS 3.6.8) in that the Enclosure Building forms a secondary boundary to containment. The difference between the design functions is that Seabrook's Containment Enclosure Building is maintained at a negative pressure following an accident (emphasis added), not prior to the event as is assumed for the STS design function. Consequently, the Seabrook Containment Enclosure Building Integrity technical specification 3.6.5.2 permits breaching the boundary in SR 3.6.5.2 during "normal transit entry and exit" through the single door access openings.

The licensee response also compared the Seabrook TS proposed required actions for an inoperable Containment Enclosure Building to STS required actions for an inoperable Shield Building. The comparison discussed that Shield Building TS 3.6.8 requires SR 3.6.8.4 to be performed and met to demonstrate Shield Building operability. SR 3.6.8.4 verifies that the Shield Building can be maintained at a specified negative pressure with a specified air flow within a specified time following receipt of actuation signal by the Shield Building Air Cleanup System (TS 3.6.13). The licensee concluded that the primary purpose of the STS SR 3.6.8.4 is to ensure Shield Building integrity (emphasis added), i.e., operability. Compared to the STS, the Seabrook Containment Enclosure Emergency Air Cleanup System (CEEACS) SR 4.6.5.1 .d.4 demonstrates the CEEACS (TS 3.6.5.1) is operable by verifying the CEEACS system produces a negative pressure of greater than or equal to 0.25 inch Water Gauge in the annulus within 4 minutes after a start signal. The licensee concluded that the primary purpose of proposed required Action b for CEEACS is to allow a 24 allowed outage time for both air-handling trains inoperable due to an inoperable boundary (emphasis added). For Seabrook, only the Containment Enclosure Building operability is affected when doors are opened, except for normal transit entry and exit. Thus, boundary integrity allowed outage time allowances are addressed differently in STS as compared to proposed Seabrook TS required actions.

1

Enclosure Response to Request for Additional Information (RAI)

Seabrook TS definition 1.21, "Operable/Operability" requires:

A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s), and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing their related support function(s).

In accordance with the regulations under 10 CFR 50.36(c)(2(i), "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." Also under 10 CFR 50.36(c)(3),

"Surveillance requirements are requirements relating to test [..] to assure that the necessary quality of systems and components is maintained, [...] and that the limiting conditions for operation will be met."

Based on the RAI response the NRC staff considered that Seabrook CEEACS, Shield Building and Structural Integrity TS surveillances do not matchup with STS SBACS and Shield Building surveillances. For Seabrook, only the Containment Enclosure Building operability is affected when doors are opened, except for normal transit entry and exit. Specifically, STS Shield Building SR 3.6.8.4 demonstrates that the Shield Building is operable by verifying that the Shield Building Air Cleanup System (TS 3.6.13) will maintain the Shield Building at a pressure equal to or more negative than [-0.5] inch water gauge in the annulus with final flow < [ ] cfm within [22]

seconds after a start signal. Contrary to STS, Seabrook CEEACS SR 4.6.5.1 .d.4 demonstrates the CEEACS is operable by verifying the CEEACS system produces a negative pressure of greater than or equal to 0.25 inch Water Gauge in the annulus within 4 minutes after a start signal. Thus, boundary integrity allowed outage time allowances are addressed differently in STS as compared to proposed Seabrook TS required actions.

Please provide additional justification for why Seabrook SR 4.6.5.1 .d.4 demonstrates operability of the Seabrook CEEACS or propose other TS changes such that this negative pressure test is associated with demonstrating operability of the Containment Enclosure Building Integrity (LCO 3.6.5.2).

2

Enclosure Response to Request for Additional Information (RAI)

Response to Question 1 NextEra proposes to change the Technical Specifications (TS) so that surveillance requirement (SR) 4.6.5.1 .d.4 will demonstrate integrity of the containment enclosure building rather than operability of the containment enclosure emergency air cleanup system (CEEACS). Specifically, SR 4.6.5.1 .d.4 will be relocated with modifications as new SR 4.6.5.2.b:

At least once per 36 months on a STAGGERED TEST BASIS by verifying the containment enclosure building can be maintainedat a negative pressuregreater than or equal to 0. 25 inch Water Gauge by one train of the containment enclosure emergency air cleanup system within 4 minutes after a start signal.

New SR 4.6.5.2.b varies from existing SR 4.6.5.1 .d.4 to reflect that the new SR is a test of containment enclosure building integrity. Consequently, the test does not need to be performed with each train of the CEEACS, so the new SR specifies that the test is performed with one train of the CEEACS. Further, inoperability of the CEEACS by itself does not constitute a failure to meet new SR 4.6.5.2.b. In other words, a failure to meet the limiting condition for operation (LCO) of TS 3.6.5.1 for the CEEACS does not necessarily result in a failure to meet LCO 3.6.5.2 for containment enclosure building integrity. Similarly, a failure to meet LCO 3.6.5.2 for containment enclosure building integrity does not render the CEEACS inoperable. With containment enclosure building integrity not maintained, only containment enclosure building operability is affected. The proposed change removes the dependence between LCO 3.6.5.1 and 3.6.5.2.

The result of eliminating the dependence between the two TS is that inoperability of either the CEEACS or the containment enclosure building requires entering only the Action of the applicable TS (TS 3.6.5.1 or 3.6.5.2, respectively). For example, only the action of TS 3.6.5.2 would be entered for an inoperable containment enclosure building.

As a result of eliminating the dependence, TS definition 1.31, CONTAINMENT ENCLOSURE BUILDING INTEGRITY, requires a change to provide consistency with the revised TS. The definition states in part that containment enclosure building integrity exists when "...The Containment Enclosure Emergency Air Cleanup System is Operable..." However, operability of the CEEACS has no impact on the integrity of the containment enclosure building. Integrity exists regardless of whether the CEEACS is operable when, as described in the current TS Bases, the containment enclosure boundary doors are closed except during normal transit and when the containment enclosure boundary pressure seals are intact. Therefore, NextEra proposes two changes regarding definition 1.31 for containment enclosure building integrity. First, because the term CONTAINMENT ENCLOSURE BUILDING INTEGRITY appears only in TS 3.6.5.2 and not throughout the TS, the definition is deleted and the requirements for integrity will be specified in the TS Bases. Second, the Bases will not stipulate that containment building enclosure building integrity is contingent on operability of the CEEACS.

3

Enclosure Response to Request for Additional Information (RAI)

The frequency of new SR 4.6.5.2.b is once per 36 months on a STAGGERED TEST BASIS. As discussed in the proposed Bases change, this staggered frequency ensures that either train of the CEEACS will perform the test. The Seabrook TS define STAGGERED TEST BASIS as:

a. A test schedule for n systems, subsystems, trains, or other designated components obtained by dividing the specified test interval into n equal subintervals, and

b. The testing of one system, subsystem, train, or other designated component at the beginning of each subinterval.

Applying a 36-month frequency on a STAGGERED TEST BASIS requires that the test be performed every 18 months using alternating trains of the CEEACS.

Question 2 The licensee's September 16, 2011, response to the NRC staff s request for additional information compared the Seabrook containment to the containment arrangements addressed in NUREG-1431. The discussion concluded that Seabrook's containment enclosure building is similar to the shield building described in NUREG- 1431.

The shield building functions to ensure proper operation of the Shield Building Air Cleanup System (SBACS) and to limit radioactive leakage from the containment to those paths and leakage rates assumed in the accident analysis. SBACS functions to ensure that radioactive materials that leak from the primary containment into the shield building following a design basis accident are filtered and absorbed prior to exhausting to the environment. NUREG-143 1, STSs 3.6.8 and 3.6.13 provide the specific requirements for the shield building and SBACS, respectively, to ensure they meet the intended functions.

In establishing the shield building requirements, the staff describes in the Bases of STS 3.6.8 that the intent is to not breach the shield building boundary at any time when the shield building is required. The staff indicates this is achieved by maintaining the barrier closed at all times. The staff also describes that shield building access doors are normally kept closed, except when the access opening is being used for entry and exit or when maintenance is being performed on an access opening. In establishing the SBACS requirements, the staff describes in the Bases of STS 3.6.13 that in the event of a design basis accident, one SBACS train is required to provide the minimum particulate iodine removal assumed in the safety analysis.

The proposed change attempts to model the TS requirements for the Seabrook containment enclosure building and the containment enclosure emergency air cleanup system to be consistent with NUREG-1431 requirements for the shield building and SBACS. The proposed changes include the insertion of a note to Seabrook TS 3.6.5.1 which states: "The containment enclosure boundary doors may be opened for normal transit under administrative control."

4

Enclosure Response to Request for Additional Information (RAI)

Based on the background provided above, please provide a justification for the proposed note to provide assurance consistent with STSs 3.6.8 and 3.6.13 that radioactive leakage from the containment will be limited to those paths and leakage rates assumed in the accident analysis.

Response to Question 2 Based on the proposed TS change discussed in the response to question 1, NextEra proposes to delete the note that modified the LCO for TS 3.6.5.1, Containment Enclosure Emergency Air Cleanup System. The purpose of the note was to permit continued operability of the CEEACS during the period that a containment enclosure boundary door is open for normal transit. The need for this note was based on the notion that if a containment enclosure boundary door was open, the negative pressure test required by SR 4.6.5.1 .d.4 could not be met, and therefore, both trains of the CEEACS would be inoperable. However, relocating the SR for the negative pressure test to TS 3.6.5.2 as a test of containment enclosure building integrity rather than a demonstration of CEEACS operability eliminates the need for the note. With regard to TS 3.6.5.2, Containment Enclosure Building Integrity, transit through the containment enclosure boundary doors does not result in a conflict with the requirement to maintain integrity. To verify building integrity, SR 4.6.5.2 requires that the door in each access opening is closed except when the access opening is being used for normal transit entry and exit.

In response to question 4 in the NRC's August 5, 2010 request for additional information regarding this license amendment request (Reference 2 on the cover letter for this submittal), NextEra discussed normal transit through containment enclosure building doors. The response discussed that the time allowed for normal transit is five minutes or less and included this information in the proposed TS Bases. NextEra proposes to remove the 5 minute criterion from the Bases and replace it with a statement similar to that included in the Bases for the shield building in NUREG- 1431, Standard Technical Specifications - Westinghouse Plants: The containment enclosure boundary doors are normally maintained closed except when the access opening is being used for entry and exit.

Normal transit through the containment enclosure boundary doors includes opening doors as necessary to permit the movement of people and equipment through the doorway. A station procedure provides directions for the actions personnel must take when passing through doors inside the protected area of the plant. These actions include ensuring the door is closed and latched following transit and immediately notifying the control room if a door cannot be closed or latched. In addition, an open containment enclosure boundary door initiates an alarm in Security, and procedures require security personnel to notify the control room upon receipt of a door alarm.

Propping open a containment enclosure boundary door or obstructing the doorway with equipment, cables, hoses, etc., such that it cannot be immediately closed is not normal transit entry and exit. If it becomes necessary to open a containment enclosure boundary 5

Enclosure Response to Request for Additional Information (RAI) door to perform maintenance on the access opening or to support maintenance on equipment within the containment enclosure, the 24-hour Action of TS 3.6.5.2 would be applicable. However, consistent with TS 3.0.1, the Action of TS 3.6.5.2 will not be used as an operational convenience which permits routine, voluntary removal of systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

6

Enclosure Attachment I Markup of the Technical Specifications

INDEX 1.0 DEFINITIONS SECTION PAGE 1.1 ACTION 1-1 1.2 ACTUATION LOGIC TEST .................................... 1-1 1.3 ANALOG CHANNEL OPERATIONAL TEST ........................ 1-1 1.4 AXIAL FLUX DIFFERENCE .................................... 1-1 1,5 CHANNEL CALIBRATION ..................................... 1-1 1,6 CHANNEL CHECK .......................................... 1-1 1,7 CONTAINMENT INTEGRITY ................................... 1-2 1,8 CONTROLLED LEAKAGE ..................................... 1-2 1,9 CORE ALTERATION ......................................... 1-2 1.10 CORE OPERATING LIMITS REPORT ............................ 1-2 1,11 DIGITAL CHANNEL OPERATIONAL TEST ......................... 1-2 1,12 DOSE EQUIVALENT 1-131 ..................................... 1-3 1,13 P-- AVERAGE DISINTEGRATION ENERGY 1-3 1,14 ENGINEERED SAFETY FEATURES RESPONSE TIME ................ 1-3 1.15 FREQUENCY NOTATION ..................................... 1-3 1,16 GASEOUS RADWASTE TREATMENT SYSTEM ..................... 1-3 1,17 IDENTIFIED LEAKAGE ....................................... 1-3 1,18 MASTER RELAY TEST 1-4 1,19 MEMBER(S) OF THE PUBLIC ............................................................................. 1-4 1,20 OFFSITE DOSE CALCULATION MANUAL 1-4 1.21 OPERABLE-OPERABILITY ................................... 1-4 1,22 OPERATIONAL MODE - MODE ................................ 1-4 1.23 PHYSICS TESTS 1-4 1.24 PRESSURE BOUNDARY LEAKAGE ............................. 1-4 1 25 PRCESS C NTROL ROGRAM..................................................................... -

1.25 PROCESS CONTROL PROGRAM 1-5 1.26 PURGE - PURGING ......................................... 1-5 1.27 QUADRANT POWER TILT RADIO ............................... 1-5 1.28 RATED THERMAL POWER...................,-... 1-5 1.29 REACTOR TRIP SYSTEM RESPONSE TIME.".ldi.'.. 1-5 1.30 REPORTABLE EVENT 1-5 1.31 C-CNT-ANMBNW ENrOS REU Ed NG1M_ ................................... 1-5 1.32 SHUTDOWN MARGIN 1-6 133 SITE BOUNDARY .. .............................................. .......................................... 1-6 1.34 SLAVE RELAY TEST ........................................ 1-6 1.35 (NO T USED) .......................................................................................................... 1-6 1.36 SOURCE CHECK ........................................... 1-6 1.37 STAGGERED TEST BASIS .................................... 1-6 1.38 THERMAL POWER ......................................... 1-6 1.39 TRIP ACTUATING DEVICE OPERATIONAL TEST... ................................ 1-6 1.40 UNIDENTIFIED LEAKAGE .................................... 1-7 1.41 UNRESTRICTED AREA ...................................... 1-7 1.42 (NO T US ED) ........................................................................................................... 1-7 1.43 VENTING ................................................ 1-7 TABLE 1.1 FREQUENCY NOTATION ................................. 1-8 TABLE 1.2 OPERATIONAL MODES .................................. 1-8 SEABROOK - UNIT 1 Amendment No. P, 66

DEFINITIONS REPORTABLE EVENT 1.30 A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 of 10 CFR Part 50.

1.31 CONTAINMENT ENCLOSURE BUIL G INTEGRITY shall exist when:

a. Each do 'eahacce peiS is los xet when the c*ess opening bein sed for nor ransit entry a exit,

b. The Contai ent Enclosure ergency Air Cle p System is OP BLE, and

c. The sealing me nism associated iteach penetrati (e.g., welds ellows, or 0-rings) is PERABLE.

SHUTDOWN MARGIN 1.32 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full-length rod cluster assemblies (shutdown and control) are fully inserted except for the single rod cluster assembly of highest reactivity worth which is assumed to be fully withdrawn.

SITE BOUNDARY 1.33 The SITE BOUNDARY shall be that line beyond which the land is neither owned, nor leased, nor otherwise controlled by the licensee.

SLAVE RELAY TEST 1.34 A SLAVE RELAY TEST shall be the energization of each slave relay and verification of OPERABILITY of each relay. The SLAVE RELAY TEST shall include a continuity check, as a minimum, of associated testable actuation devices.

1.35 (NOT USED)

SOURCE CHECK 1.36 A SOURCE CHECK shall be the qualitative assessement of channel response when the channel sensor is exposed to a source of increased radioactivity.

SEABROOK - UNIT 1 1-6 Amendment No. -7,-9, W 81

CONTAINMENT SYSTEMS 3/4.6.5 CONTAINMENT ENCLOSURE BUILDING CONTAINMENT ENCLOSURE EMERGENCY AIR CLEANUP SYSTEM LIMITING CONDITION FOR OPERATION 3.6.5.1 Two independent Containment Enclosure Emergency Air Cleanup System/shall be OPERABLE.

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

ACTION:

With one Containm Enclosure Emergency Air Cleanup System inoperable, restore the inoperable o 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 />.

SURVEILLANCE REQUIREMENTS 4.6.5.1 Each Containment Enclosure Emergency Air Cleanup System s!hll be demonstrated OPERABLE:

a. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes;

b. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:

1) Verifying that the cleanup system satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978*, and the system flow rate is 2100 cfm +/- 10%;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, by showing a methyl iodide penetration of less than or

/# The 7-day allo yd outage tap which w aentered o une 4, 20 at 0602 *urs,

{ exended *rtime by 3-addition a*7days to cpm5ete rep,i-nd test in nthe "nirment Enclos'die Ventil iton Area ret, asli fan EA Con -1B

/b bmay*

• ANSI N510-1980 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52, Rev. 2, March 1978.

SEABROOK - UNIT 1 3/4 6-21 Amendment No. 7-5,444-

CONTAINMENT SYSTEMS CONTAINMENT ENCLOSURE BUILDING CONTAINMENT ENCLOSURE EMERGENCY AIR CLEANUP SYSTEM SURVEILLANCE REQUIREMENTS 4.6.5.1 b.2 (Continued) equal to 5% when tested at a temperature of 30 0 C, at a relative humidity of 95% and a face velocity of 46 fpm in accordance with ASTM-D3803-1989; and

3) Verifying a system flow rate of 2100 cfm +/- 10% during system operation when tested in accordance with ANSI N510-1980.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory A Guide 1.52, Revision 2, March 1978, by showing a methyl iodide penetration of less than or equal to 5% when tested at a temperature of 30 0 C, at a relative humidity of 95% and a face velocity of 46 fpm in accordance with ASTM-D3803-1989.

d. At least once per 18 months by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the system at a flow rate of 2100 cfm +/- 10%,

2) Verifying that the system starts on a Safety Injection test signal,

3) Verifying that the filter cross connect valves can be manually openecd.

(4) erifying theach systeqm produces gative p;ssure oorea r than qual to 0..,5-ich Water uge in annul hi utes after a-tart signal.

e. After each complete or partial replacement of a high efficiency particulate air (HEPA) filter bank, by verifying that the cleanup system satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a dioctyl phthalate (DOP) test aerosol while operating the system at a flow rate of 2100 cfm +/- 10%; and SEABROOK - UNIT 1 3/4 6-22 Amendment No. "t

CONTAINMENT SYSTEMS CONTAINMENT ENCLOSURE BUILDING ._.

CONTAINMENT ENCLOSURE BUILDING INTEGRITY e,,7,l.0a ,,,4 LIMITING CONDITION FOR OPERATION 3.6.5.2 CC.9 AIIWMENT E4e(OSURP-ESUILDINIe-NTeID sh II be maintained.

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

ACTION: i/ / -'?

Without TA4N M EENCLOJ II" NT R-rTYD testoreigý ý -A-ý

..*SU;E BJILD,*G *rwithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in a 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 fol owing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.5.2 (651A_!Nl T ENedSURF-B1ILD. 'TEN*

• shall be demonstrated eas per days by verifying that the door in eac access opening is closed excep when the access o ening is being used for normal transit entry and exit, eI' al

l. o-i/ e y,, 4.* ,,,,b,4 4~ .- ,rIe 0- /4 e-

£2 .t6,4C# 2j-64 'e,/'~7',

SEABROOK - UNIT 1 3/4 6-24

Enclosure Attachment 2 Proposed Bases Changes

CONTAINMENT SYSTEMSy90.

BASES 3/4.6.5 CONTAINMENT ENCLOSURE BUILDING 3/4.6.5.1 CONTAINMENT ENCLOSURE EMERGENCY AIR CLEANUP SYSTEM "TheOPERABILITY of the Containclosure Emergency Air Cleanup System ensures that during LOCA conditi ontainment vessel leakage into the annulus, and radioactive materials leaki om engineered safety features equipmen ,m the electrical penetration areas, rom the mechanical penetration tunnel, " e filtered through the HEPA filters charcoal adsorber trains prior to dischar the atmosphere.

e EAH system components associated ithis Technical Specification include t e dampers, fans, filters, etc., and requi ductwork and instrumentation that evacuate or isolate areas, route air, and filter th haust prior to discharge to the environment.

Included among these compone are:

0 Containment e r~tsure cooling fans (EAH-FN-5A and 5B)/

• Containme nclosure ventilation area return fans (E ,, N-31A and 31B)

• Contai :Ifent enclosure emergency exhaust fn FN-4A and 4B)

C ig up omaetr arfasEAH-F 8OA and 180B) "

/ ° PAB / CEVA isolation dampers (P - P-35A, 36A, 35B, and 36B) -

The EAH system also provides ling to the following areas and e i ment during.

normal and emergency operation: ntainment enclosure ventilatione ipment area, the- .

charging pumps, safety injec pumps, residual heat removal p ps, containment spray pumps, and the mechanical penetration area. However, the H cooling function is not associated with this Technical Specification, but rather is ontrolled under Technical Requirement 24, Area Temperature Monitoring.

3/4.6.5.2 CONTAINMENT ENCLOSURE BUILDING INTEGRITY CONTAINMENT ENC URE BUILDING INTEGRITY ensures that the release of radioactive material the primary containment at re will be restricted to those leakage pat associated leak rates assu in the safety analyses. This restriction, in

/ conju n with operation imit th STEBOUNDARY ra 6i the Contai nt Enclosure Emergency Air Cleanup System, o doses to within the dose guid vlues of 10

! CFR 50.67 during accidetitions.

Verifying tha enclosure boundary is intact, as integrity, involves confirmi g that the dos coe xetdrn omlt i nr n xt omlt include ngdosa eesr op hemvmn fpol qimn throu the doorway. This may also' ude opening doors to confi ~actuation of door alarms and for other activities th o not interfere with the a of the door to immedi y close and seal. Propping o a door and obstructing oorway with equipme , ables, hoses, etc., such that it nnot be immediately clo is not normal transitepý and exit.

Additionally, pressure boundary seals must als e intact to maintain tbeintegrity of the containment enclosure.

SEABROOK - UNIT 1 B 3/4 6-5 Amendment No. 49, BC 04 05, 04-06, 04-1-2, 08-02, 10-02

BASES INSERT 1 3/4.6.5.1 CONTAINMENT ENCLOSURE EMERGENCY AIR CLEANUP SYSTEM (CEEACS)

BACKGROUND The CEEACS is designed to maintain a negative pressure of greater than or equal to 0.25 inches of water, following a design basis accident, in the annular region defined by the containment structure and the containment enclosure, as well as in the additional building volumes associated with the electrical penetration areas, mechanical piping penetration area and engineered safeguard equipment cubicles. Any fission products leaking from these systems and from the primary containment will be retained in these areas and eventually processed through the filters.

The filter system consists of redundant filter trains, fans, dampers and controls and a common ductwork system. The air flow required to maintain a negative pressure in the containment enclosure building is passed through dernisters, which also function as prefilters, and through HEPA filters located both upstream and downstream of the carbon filter prior to exhausting through the plant vent. A ductwork cross-connection is provided between the two filter trains at a point between the downstream HEPA filter and the fan inlet. Should the operating fan fail, this cross-connection will insure a continued air flow by manual startup of the redundant fan. Each redundant filter train is complete, separate and independent from both electrical and.control standpoints. Each filter train fan is supplied power from an independent power source.

APPLICABLE SAFETY ANALYSIS The CEEACS ensures that, during LOCA conditions, containment vessel leakage into the annulus, and radioactive materials leaking from engineered safety features equipment, the electrical penetration areas, and the mechanical penetration tunnel, will be filtered through the HEPA filters and charcoal adsorber trains prior to discharge to the atmosphere. In the event of an accident requiring CEEACS operation, both of the redundant filter train fans will be automatically started on a "T" signal. One train of the CEEACS is required to draw down the entire containment enclosure area to a negative differential pressure of 0.25 inches of water. This differential pressure is required to be established between all areas that comprise the containment enclosure area and their external surroundings.

Analysis has shown that one containment enclosure exhaust filter fan is capable of drawing down the entire containment enclosure area to the design negative differential pressure in less than 8 minutes after the initiation of a design basis LOCA. This analysis takes into account the engineered safety feature actuation system signal delay time, delay time for the diesel generator to supply power in the event of a simultaneous loss of offsite power, and the time for the filter fan to come up to speed.

The CEEACS satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

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LCO One train of the CEEACS is required to maintain a negative pressure within the containment enclosure following an accident, to remove and retain airborne particulates and radioactive iodine, and to exhaust filtered air to the unit plant vent. Two trains of the CEEACS must be OPERABLE to ensure that at least one train will operate assuming that the other train is disabled by a single active failure. When the LCO for the CEEACS is not met, it is not necessary to declare LCO 3.6.5.2 for containment enclosure building integrity not met.

The CEEACS also provides cooling to the following areas and equipment during normal and emergency operation: containment enclosure ventilation equipment area, the charging pumps, safety injection pumps, residual heat removal pumps, containment spray pumps, and the mechanical penetration area. However, the cooling function is not associated with this TS, but rather is controlled under Technical Requirement 24, Area Temperature Monitoring.

The components associated with this TS include those dampers, fans, filters, etc., and required ductwork and instrumentation that evacuate or isolate areas, route air, and filter the exhaust prior to discharge to the environment. Included among these components are:

• Containment enclosure cooling fans (EAH-FN-5A and 5B)

• Containment enclosure ventilation area return fans (EAH-FN-3 1A and 31 B)

• Containment enclosure emergency exhaust fans (EAH-FN-4A and 4B)

" Charging pump room return air fans (EAH-FN- 180A and 180B)

" Containment enclosure emergency clean up filters (EAH-F-9 and F-69)

" PAB / CEVA isolation dampers (PAH-DP-35A, 36A, 35B, and 36B)

APPLICABILITY In MODES 1, 2, 3, and 4, a design basis accident (DBA) could lead to fission product release to containment that leaks to the containment enclosure building. In MODES 5 and 6, the probability and consequences of a DBA are low due to the pressure and temperature limitations in these MODES. Under these conditions, the CEEACS is not required to be OPERABLE ACTION The Action requires that with one CEEACS train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The 7 day completion time considers the availability of the OPERABLE redundant CEEACS train and the low probability of a design basis accident occurring during this period. If the CEEACS train cannot be restored to OPERABLE status within the 7 days, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The completion times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant.

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BASES INSERT 2 3/4.6.5.2 CONTAINMENT ENCLOSURE BUILDING INTEGRITY BACKGROUND Located outside the containment building and having a similar geometry is the containment enclosure building. The enclosure building is a reinforced concrete right cylindrical structure with a hemispherical dome. This structure provides leak protection for the containment and protects it from certain loads. The space between the containment and the enclosure building is maintained at a slight negative pressure during accident conditions. All joints and penetrations are sealed to ensure air tightness.

APPLICABLE SAFETY ANALYSES The function of the containment enclosure building is to collect any fission products which could leak from the primary containment structure into the containment enclosure and contiguous areas following a LOCA. The containment enclosure provides a low leakage rate barrier between the containment and the environment to control all leakage from the containment boundary.

Containment enclosure building integrity ensures that the release of radioactive materials from the primary containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses. This restriction, in conjunction with operation of the containment enclosure emergency air cleanup system (CEEACS), will limit the SITE BOUNDARY radiation doses to within the dose guideline values of 10 CFR 50.67 during accident conditions.

The containment enclosure building satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO Containment enclosure building integrity must be maintained to limit the release of radioactive materials from the primary containment atmosphere to those leakage paths and associated leak rates assumed in the safety analyses. Containment enclosure building integrity exists when (1) each door in each access opening is closed except when the access opening is being used for normal transit entry and exit, and (2) the sealing mechanism associated with each penetration (e.g., welds, bellows, or 0-rings) is OPERABLE.

APPLICABILITY Maintaining containment enclosure building integrity prevents leakage of radioactive material from the enclosure building. Radioactive material may enter the containment enclosure building from the containment following a DBA. Therefore, containment enclosure integrity is required in MODES 1, 2, 3, and 4 when a DBA could release radioactive material to the containment 3.

atmosphere. In MODES 5 and 6, the probability and consequences of these events are low due to the Reactor Coolant System temperature and pressure limitations in these MODES. Therefore, containment enclosure building integrity is not required in MODE 5 or 6.

ACTION In the event containment enclosure building integrity is not maintained, integrity must be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Twenty-four hours is a reasonable completion time considering the limited leakage design of containment and the low probability of a DBA occurring during this time.

Inoperability of the containment enclosure building does not render the CEEACS inoperable.

Therefore, the Action of TS 3.6.5.1 (CEEACS) is not required to be entered solely due to a failure to maintain containment enclosure building integrity.

SURVEILLANCE REQUIREMENTS SR 4.6.5.2.a The containment enclosure boundary doors are normally maintained closed except when the access opening is being used for entry and exit. Verifying containment enclosure building integrity involves confirming that the doors are closed except during normal transit entry and exit. Normal transit includes opening doors as necessary to permit the movement of people and equipment through the doorway. This may also include opening doors to test actuation of door alarms. Propping open a door and obstructing the doorway with equipment, cables, hoses, etc.,

such that it cannot be immediately closed is not normal transit entry and exit. Additionally, pressure boundary seals must also be intact to maintain the integrity of the containment enclosure.

SR 4.6.5.2.b The CEEACS produces a negative pressure in the containment enclosure building. SR 4.6.5.2 verifies that the building can be drawn down to a negative pressure greater than or equal to 0.25 inch Water Gauge using one train of CEEACS within 4 minutes after a start signal. The time limit ensures the building is at its design negative pressure in less than 8 minutes following the initiation of a LOCA.

Since this SR is a containment enclosure building boundary integrity test, it does not need to be performed with each CEEACS train. The CEEACS train used for this SR is staggered to ensure that either train will perform the test. The primary purpose of this SR is to ensure containment enclosure building integrity. The secondary purpose of this SR is to ensure that the CEEACS train used for the test functions as designed. Inoperability of the CEEACS train does not necessarily constitute a failure of this SR relative to containment enclosure building integrity.

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