ML15082A233

Issuance of Amendment Regarding Increase Voltage Limit for Diesel Generator Load Rejection Surveillance Requirement

ML15082A233
Person / Time
Site:	Seabrook
Issue date:	04/24/2015
From:	John Lamb Plant Licensing Branch 1
To:	Dean Curtland NextEra Energy Seabrook
Lamb J, NRR/DORL/LPLI-2, 415-3100
References
TAC MF4578
Download: ML15082A233 (17)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Apri 1 24, 2015 Mr. Dean Curtland, Site Vice President c/o Michael Ossing Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 0387 4

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT REGARDING INCREASE VOLTAGE LIMIT FOR DIESEL GENERATOR LOAD REJECTION SURVEILLANCE REQUIREMENT (TAC NO. MF4578)

Dear Mr. Curtland:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 147 to Facility Operating License No. NPF-86 for the Seabrook Station, Unit No. 1 (Seabrook). This amendment consists of changes to the facility technical specifications (TSs) in response to your application dated July 24, 2014, as supplemented by letters dated December 11, 2014, and January 9, 2015.

The amendment increases the voltage limit for a full load rejection test of the emergency diesel generator specified in surveillance requirement 4.8.1.1.2.f.3 of TS 3.8.1.1, "A.C. Sources -

Operating." The amendment also revises the TS definition of the terms "Operable - Operability."

A copy of our safety evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sier~g~

icensing Branch 1-2 1

v* ion of Operating Reactor Licensing 0 ice of Nuclear Reactor Regulation Docket No. 50-443

Enclosures:

1. Amendment No. 147 to NPF-86

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NEXTERA ENERGY SEABROOK, LLC, ET AL.*

DOCKET NO. 50-443 SEABROOK STATION. UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 147 License No. NPF-86

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by NextEra Energy Seabrook, LLC, et al.,

(the licensee) dated July 24, 2014, as supplemented by letters dated December 11, 2014, and January 9, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

• NextEra Energy Seabrook, LLC is authorized to act as agent for the: Hudson Light & Power Department, Massachusetts Municipal Wholesale Electric Company, and Taunton Municipal Light Plant and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility.

2. Accordingly, the license is amended by changes to paragraphs 2.C.(2) of Facility Operating License No. NPF-86 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 147, and the Environmental Protection Plan contained in Appendix B are incorporated into the Facility License No. NPF-86.

NextEra Energy Seabrook, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

~~

~r Douglas A. Broaddus, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and TS Date of Issuance: Apri 1 24, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 147 FACILITY OPERATING LICENSE NO. NPF-86 DOCKET NO. 50-443 Replace the following page of Facility Operating License No. NPF-86 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Insert 3 3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

Remove Insert 1-4 1-4 314 8-5 3/4 8-5

(4) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility authorized herein; and (7) DELETED C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level NextEra Energy Seabrook, LLC, is authorized to operate the facility at reactor core power levels not in excess of 3648 megawatts thermal (100% of rated power).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 147*, and the Environmental Protection Plan contained in Appendix B are incorporated into the Facility License No. NPF-86. NextEra Energy Seabrook, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) License Transfer to FPL Energy Seabrook. LLC**

a. On the closing date(s) of the transfer of any ownership interests in Seabrook Station covered by the Order approving the transfer, FPL Energy Seabrook, LLC**, shall obtain from each respective transferring owner all of the accumulated decommissioning trust funds for the facility, and ensure the deposit of such funds and additional funds, if necessary, into a decommissioning trust or trusts for Seabrook Station established by FPL Energy Seabrook, LLC**, such that the amount of such funds deposited meets or exceeds the amount required under 10 CFR 50. 75 with respect to the interest in Seabrook Station FPL Energy Seabrook, LLC**,

acquires on such dates(s).

• Implemented

• • On April 16, 2009, the name "FPL Energy Seabrook, LLC" was changed to "NextEra Energy Seabrook, LLC".

AMENDMENT NO. 147

DEFINITIONS

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of Leakage Detection Systems or not to be PRESSURE BOUNDARY LEAKAGE, or

c. Reactor Coolant System leakage through a steam generator to the Secondary Coolant System (primary to secondary leakage).

MASTER RELAY TEST 1.18 A MASTER RELAY TEST shall be the energization of each master relay and verification of OPERABILITY of each relay. The MASTER RELAY TEST shall include, a continuity check of each associated slave relay.

MEMBER(S) OF THE PUBLIC 1.19 MEMBER(S) OF THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the licensee, its contractors, or vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant.

OFFSITE DOSE CALCULATION MANUAL 1.20 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by Section 6.7.6 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.8.1.3 and 6.8.1.4.

OPERABLE - OPERABILITY 1.21 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s), and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

OPERATIONAL MODE - MODE 1.22 An OPERATIONAL MODE (i.e., MODE) shall correspond to any one inclusive combination of core reactivity condition, power level, and average reactor coolant temperature specified in Table 1.2.

SEABROOK - UNIT 1 1-4 Amendment No. +..,-9,66, 81, 115,147

ELECTRICAL POWER SYSTEMS AC. SOURCES OPERATING SURVEILLANCE REQUIREMENTS 4.8.1.1.2 (Continued)

f. In accordance with the Surveillance Frequency Control Program, during

shutdown , by:

1) (NOT USED)

2) Verifying the generator capability to reject a load of greater than or equal to 671 kW while maintaining voltage at 4160 +/-. 420 volts and frequency at 60 +/-. 4.0 Hz;

3) Verifying the generator capability to reject a load of 6083 kW without tripping. The generator voltage shall not exceed 4992 volts during and following the load rejection;

4) Simulating a loss-of-offsite power by itself, and:

a) Verifying deenergization of the emergency buses and load shedding from the emergency buses, and b) Verifying the diesel starts from standby conditions### on the loss of offsite power signal, energizes the emergency buses with permanently connected loads within 12 seconds, energizes the auto-connected shutdown loads through the emergency power sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 +/- 420 volts and 60 +/- 1.2 Hz during this test.

5) Verifying that on an SI actuation test signal, without loss-of-offsite power, the diesel generator starts from standby conditions### on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The generator voltage and frequency shall be greater than or equal to 37 40 volts and 58.8 Hz within 10 seconds after the auto-start signal; the steady-state generator voltage and frequency shall be maintained at 4160 +/- 420 volts and 60 +/- 1.2 Hz during this test; f#I. Selected surveillance requirements, or portions thereof, may be performed during conditions or modes other than shutdown, provided an evaluation supports safe conduct of that surveillance in a condition or mode that is consistent with safe operation of the plant. (Ref. NRC GL 91-04) 1#1# Starting of the diesel for Specifications 4.8.1.1.2f.4) and 4.8.1.1.2f.5) may be performed with the engine at or near normal operating temperature.

SEABROOK - UNIT 1 3/4 8-5 Amendment No. 54, 71, 73, 80, 141, 147

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 147 TO FACILITY OPERATING LICENSE NO. NPF-86 SEABROOK STATION, UNIT NO. 1 DOCKET NO. 50-443

1.0 INTRODUCTION

By letter dated July 24, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14209A918), as supplemented by letters dated December 11, 2014, and January 9, 2015 (ADAMS Accession Nos. ML14349A646 and ML15015A012, respectively), NextEra Energy Seabrook, LLC (NextEra, or the licensee) requested changes to the technical specifications (TSs) for Seabrook Station, Unit 1 (Seabrook). Specifically, the licensee requested to increase the voltage limit for a full load rejection test of the emergency diesel generator (EOG) specified in surveillance requirement (SR) 4.8.1.1.2.f.3 of TS 3.8.1.1, "A.C. Sources - Operating." The license amendment request (LAR) also requested to revise the TS definition of the terms "Operable - Operability."

By letter dated July 24, 2014, (ADAMS Accession No. ML13212A069) the Nuclear Regulatory Commission (NRC) issued Amendment No. 141 to Facility Operating License No. NPF-86 for Seabrook, which modified its TSs by relocating specific surveillance frequencies to a licensee-controlled program with implementation of Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specification Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." The changes were consistent with NRC-approved TSTF-425, "Relocate Surveillance Frequencies to Licensee Controlled [Risk Informed Technical Specifications Task Force] RITSTF Initiative 5b," Revision 3. It is noted that Seabrook has a Surveillance Frequency Control Program (SFCP).

The supplements dated December 11, 2014, and January 9, 2015, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on September 30, 2014 (79 FR 58821).

2.0 REGULATORY EVALUATION

2.1 Background The EOG was manufactured by Beloit Power Systems. It is a Type TGZOO with a nominal voltage rating of 4160 volts. The EOG voltage regulator was manufactured by Basler Electric and is a Static Exciter Regulator Model SER-CB.

Non-segregated phase bus duct is used to connect the EOG to the 4.16 kilovolts (kV) switchgear. The non-segregated phase bus duct nominal voltage rating is 4.16kV, the maximum continuous voltage rating is 4. 76kV, the one minute dry withstand voltage rating is 19kV root mean square (rms), and the full wave impulse withstand voltage rating is 60kV.

The switchgear nominal voltage rating is 4.16kV, the maximum continuous voltage rating is

4. 76kV, the one minute low frequency withstand voltage rating is 19kV rms, and the full wave impulse withstand voltage rating is 60kV.

As stated in the updated final safety analysis report (UFSAR), Section 8.3.1.1.e, two redundant EOG systems of identical design and characteristics supply standby onsite power of sufficient capacity and capability to reliably shut down the reactor. The continuous load rating of each EOG is 6083 kilowatts (kW) for 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> per year and the short time load rating is 6697 kW.

The generator itself is rated 8375 kilovolt-amperes (kVA) at 0.8 power factor (pf) lagging continuous, with a 2-hour short time rating of 9213 kVA at 0.8 pf. Each EOG is connected to a 4160-volt emergency bus. The capacity of each EOG is sufficient to meet the safety features demand caused by a loss of offsite power with or without a coincident loss-of-coolant accident.

The EOG may experience a full load rejection because of a system fault or an inadvertent EOG breaker trip during an event. The Seabrook TS requires testing the EOG performance per SR 4.8.1.1.2.f.3 to demonstrate the capability of the EOG to reject load equal to the continuous load rating of the EOG (6083 kW) without tripping or sustaining damage. This testing ensures that the EOG will be immediately available to perform its required functions after the event, including reconnection to the bus if the trip initiator can be corrected or isolated. The load rejection test envelopes the voltage and frequency variations that will be observed during a partial to full load (6083 kW) rejection event with the EOG connected to the safety buses. The TS SR 4.8.1.1.2.f.3 currently specifies an overvoltage limit of 4784 volts (V) for the EOG during and following the full load rejection test.

In the LAR, the licensee stated that the current TS overvoltage limit of 4784 V, which is equal to 115 percent of the nominal bus voltage of 4160 V, has no technical basis in any applicable industry or regulatory standards, and has resulted in past test failures. The cause of the failures was attributed to high grid voltage conditions, which resulted in corresponding high voltages on the station emergency buses. The licensee further stated that when an EOG is operated in parallel with the grid to obtain the full load value of 6083 kW for the purpose of the full load rejection test, the emergency bus voltage is further increased as excitation is adjusted to meet the required volt-ampere reactive (VAR) loading. If the steady-state bus voltage prior to the full load rejection is too high, the overvoltage transient challenges the current TS overvoltage limit.

In addition, the licensee provided a summary of previous EOG full load rejection test results that show not much margin between the transient peak voltages and the TS overvoltage limit of

4784 V. Therefore, the licensee proposed to revise the overvoltage limit for the EOG full load rejection test.

2.2 Regulatory Review The regulations in Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 or similar plant-specific principal design criteria provide design requirements. Appendix B to 10 CFR Part 50, the TSs, and the licensee quality assurance programs provide operating requirements. The regulatory requirements of 10 CFR Part 50, Appendix A, that are applicable to the onsite power system include: General Design Criteria (GDC) 2, 4, 5, 17, and 18.

Criterion 2-0esign bases for protection against natural phenomena. Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. The design bases for these structures, systems, and components shall reflect: (1) Appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area, with sufficient margin for the limited accuracy, quantity, and period of time in which the historical data have been accumulated, (2) appropriate combinations of the effects of normal and accident conditions with the effects of the natural phenomena and (3) the importance of the safety functions to be performed.

Criterion 4-Environmental and dynamic effects design bases. Structures, systems, and components important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These structures, systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit. However, dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping.

Criterion 5-Sharing of structures, systems, and components. Structures, systems, and components important to safety shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.

Criterion 17-Electric power systems. An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are

not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

Criterion 18-lnspection and testing of electric power systems. Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system.

The NRC's regulatory requirements related to the content of the TSs are contained in 1O CFR 50.36( c). The regulations in 1O CFR 50.36 require that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCO); (3) SRs; (4) design features; and (5) administrative controls. SRs 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 LCOs will be met.

The NRC's guidance for the format and content of licensee TSs can be found in NUREG-1431, "Standard Technical Specifications Westinghouse Plants." Other guidance the NRC staff used were: (1) NUREG-0800, Standard Review Plan, Chapter 16, "Technical Specifications," and (2)

Generic Letter 80-30, "Clarification of the Term 'Operable' as It Applies to Single Failure Criterion for Safety Systems Required by TS."

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes The current SR 4.8.1.1.2.f.3 reads as follows:

Verifying the generator capability to reject a load of 6083 kW without tripping.

The generator voltage shall not exceed 4784 volts during and following the load rejection; The licensee has proposed the following change to SR 4.8.1.1.2.f.3:

Verifying the generator capability to reject a load of 6083 kW without tripping.

The generator voltage shall not exceed 4992 volts during and following the load rejection; The current TS Definition 1.21, "Operable - Operability," reads as follows:

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).

The licensee has proposed the following change to TS Definition 1.21:

A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s),

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

The licensee also made an editorial change to the affected TS page to correct four instances of a misspelling of the term buses.

3.2 NRC Staff Technical Evaluation 3.2.1 Surveillance Requirements In the LAR, the licensee stated that when an EOG is operated in parallel with the grid for the purpose of the full load rejection test, the emergency bus voltage is further increased as excitation is adjusted to meet the required VAR loading. The NRC staff requested the licensee to provide the required VAR loading value for the full load rejection test and the basis for that value. In its response letter dated January 9, 2015, the licensee stated that, according to the plant procedures, the existing VAR loading requirement for the full load rejection test is 3900 kVAR (3700 - 4100 kVAR range). The selected loading verifies that the EOG surveillance is performed at a pf that represents the design load VAR as determined in the EOG loading calculation. During the EOG tests, kVAR loadings less than the limits are acceptable as long as an evaluation is performed to verify that the kVAR limitation is due to grid conditions and not to problems with the voltage regulator. The NRC staff finds the licensee response acceptable.

The NRC staff also requested the licensee to explain why the VAR loading is not included in the EOG load rejection SR 4.8.1.1.2.f.3 since the overvoltage limit is also dependent on the VAR.

In its response letter dated January 9, 2015, the licensee clarified that the existing TS overvoltage limit of 4784 V was not based on any specific VAR loading. In addition, based on its current licensing basis, Seabrook has no TS requirement for a specific VAR loading associated with the EOG full load rejection. The NRC staff finds the licensee response acceptable.

In the LAR, the licensee stated that the proposed overvoltage limit of 4992 V, which is equal to 120 percent of nominal 4160 V, will provide adequate margin based on consideration of past test results. The licensee evaluated the components potentially impacted by the overvoltage condition on full load rejection tests and determined that the proposed overvoltage limit of 4992 V would not cause any detrimental effects to these components. The licensee made this determination based on the short duration of the peak voltage transient (peak lasting 1 second and returning to steady state voltage within 4 seconds) resulting from the full load rejection, and based on the following results from the evaluation:

1. The generator was evaluated to be capable of withstanding a voltage of about 6000 V and was satisfactorily factory tested at 9300 V for 1 minute. The generator winding insulation was satisfactorily tested at 2500 V direct current. The manufacturer of the EOG confirmed that a momentary excursion to 4992 V does not pose a risk to the generator.

2. The manufacturer of the EOG voltage regulator confirmed that a momentary excursion to 4992V does not pose a risk to the generator excitation system on the basis that the excitation system of the voltage regulator is not overstressed during a full load reject.

The power transformers of the voltage regulator are rated for an overvoltage of 1.20 per unit for 10 seconds. The non-excitation system devices associated with the voltage regulator have adequate voltage ratings, and will not be degraded by the anticipated magnitude and short duration of overvoltage transient.

3. The non-segregated phase bus duct has a maximum continuous rating of 4.76 kV and a 1 minute dry withstand voltage rating of 19 kV.

4. The switchgear can operate continuously at 4.76 kV and a low frequency withstand voltage rating of 19 kV for 1 minute.

The NRG staff reviewed the licensee's evaluation and finds that: (1) the proposed overvoltage limit of 4992 V is within the short term ratings of the generator, non-segregated phase bus, and the switchgear, and (2) the EOG control components including the voltage regulator can withstand much higher voltage for a longer period of time when compared to the peak voltage and duration of the transient. Based on the above, the NRG staff concludes that transient voltages up to 4992 V would not adversely affect the EOG and associated components or the capability of the EOG to perform their intended function. Therefore, the NRG staff finds the proposed overvoltage limit acceptable.

The NRG staff also finds the proposed correction of the word "busses" (misspelled) to "buses" in four instances on the affected TS page (3/4 8-5) acceptable.

3.2.2 TS Operable-Operability Definition Change The definition of Operable - Operability is included in the TS as an aid in the licensee's determinations per their quality assurance program if structures, systems and components of the facility have become degraded or reach a condition of nonconformance with the TS.

In its letter dated July 24, 2014, the licensee proposed to revise the definition of operable-operability to be consistent with the definition in NUREG-1431, Vol. 1, Rev. 4, "Standard Technical Specifications for Westinghouse Plants" (ADAMS Accession Number ML12100A222).

The current definition in the Seabrook TS requires electrical power be capable of performing its required support function. The licensee proposes to change the definition to add the words "normal or emergency" before "electrical power" to explicitly identify the power sources needed to support system operability. The licensee also proposes to make the following changes:

(1) specify that a system, subsystem, train, component, or device shall be capable of performing its specified "safety" function; (2) change "or" to "and" in the list of support systems, and (3) require that support systems shall be capable of performing their "specified safety" function.

The markup below indicates these changes (underlined portion indicates added words).

A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s),

and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling eF and seal water, lubrication eF, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

The revised definition of Operable-Operability is shown below:

A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s),

and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train,

component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

The NRC staff reviewed the proposed change. Per information identified on page 524 of NUREG-0896, March 1983, "Safety Evaluation Report related to the operation of Seabrook Station, Units 1 and 2," the TS for this facility were originally based on "Standard Technical Specifications for Westinghouse Pressurized Water Reactors" (NUREG-0452, Revision 4 ).

Prior to the issuance of Generic Letter (GL) 80-30, "Clarification of the Term 'Operable' as It Applies to Single Failure Criterion for Safety Systems Required by TS," in April of 1980, there may have been variance in the ways specific plants applied TS, especially regarding an inoperable emergency power support system. In addition, some plants with custom TS did not specifically address the need for emergency power systems during shutdown. Emergency power is usually provided by onsite emergency diesel generators. GL 80-30 asked that all facilities incorporate language into their TS to address this issue. Specifically, a definition of OPERABLE-OPERABILITY was provided that included" ... normal and emergency electric power ... " and a Limiting Condition of Operation (LCO) 3.0.5 was included to address the specific situation of the loss of a supporting emergency electric power source by ensuring that any redundant "... train(s), component(s) and device(s) ... "were operable. Otherwise, a unit shutdown was required.

By the fall of 1981 when NUREG-0452, Revision 4, standard technical specifications (STS) were issued, the GL 80-30 guidance was written into STS by revising the definition of OPERABLE-OPERBILITY to include only" ... electric power .... " The specific actions for an inoperable emergency power source were revised to include an action that verifies that redundant components are operable. Redundant equipment depends on the other emergency power source which is also required to be operable. Seabrook TS specifically meets these requirements in ACTION d. of LCO 3.8.1.1 and SR 4.8.1.1.2a.5 of their current TS. Additionally, Seabrook TS specifically require a shutdown emergency power source to be operable in LCO 3.8.1.2b.

The current NUREG 1431, Vol. 1, Rev. 4, STS have LCO 3.0.6, which is similar to the circa 1980 LCO 3.0.5. Since the Seabrook TS were written based on NUREG-0452, Rev. 4, this definition change is compatible with the STS in NUREG 1431, Vol. 1, Rev. 4. Overall, the NRC staff concludes that the requested changes do not change the intent of the definition of Operable-Operability and are consistent with the STS in NUREG-1431. Therefore, the NRC staff concludes that these changes are acceptable.

3.3 NRC Staff Technical Conclusion The NRC staff reviewed the licensee's proposed changes to the full load rejection test of the EOG specified in TS SR 4.8.1.1.2.f.3 and to the definition of the terms of Operable - Operability in TS 1.21. The changes would increase the allowed generator voltage limiting value during the full load rejection and would clarify the definition of the terms operable and operability with regard to electrical power. Based on the evaluation above, the NRC staff concludes that the proposed TS changes would continue to provide reasonable assurance of the availability of equipment required to mitigate the consequences of an accident. The NRC staff also concludes that the proposed TS changes do not impact the licensee's continued compliance with GDC 17 and GDC 18. Therefore, the NRC staff finds the proposed changes acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New Hampshire and Massachusetts State officials were notified of the proposed issuance of the amendment. The State officials provided no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 1O CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The NRC has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published on September 30, 2014 (79 FR 58821). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 1O CFR 51.22(c)(9). Pursuant to 1O CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

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

Principal Contributors: V. Goel, A. Foli, and P. Snyder.

Date: Apri 1 24, 2015

ML15082A233 *via memo **via e-mail OFFICE LPL 1-2/PM LPL 1-2/LA STSB/BC EEEB/BC OGG LPL 1-2/BC LPL 1-2/PM A Ghosh DBroaddus NAME JLamb ABaxter** RElliott JZimmerman* (REnnis for) JLamb DATE 03/27/2015 04/16/2015 041 /2015 03/12/2015 03/31/2015 04/17/2015 04/24/2015