ML13175A197

Request for Additional Information for License Amendment Request 12-04, Application Regarding Cold Leg Injection Permissive

ML13175A197
Person / Time
Site:	Seabrook
Issue date:	06/28/2013
From:	John Lamb Plant Licensing Branch 1
To:	Walsh K NextEra Energy Seabrook
Lamb J, NRR/DORL/LPLI-2, 415-3100
References
License Amendment Request 12-04, TAC MF1158
Download: ML13175A197 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 28, 2013 Mr. Kevin Walsh, Site Vice President clo Michael O'Keefe Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT NO.1 - REQUEST FOR ADDITIONAL INFORMATION FOR LICENSE AMENDMENT REQUEST 12-04, APPLICATION REGARDING COLD LEG INJECTION PERMISSIVE (TAC NO. MF1158)

Dear Mr. Walsh:

By letter dated March 13, 2013 (Agencywide Documents Access and Management System Accession No. ML13079A122), NextEra Energy Seabrook, LLC (licensee) submitted license amendment request 12-04 for Seabrook Station, Unit No.1 (Seabrook). The proposed change is to the Seabrook Technical Specifications. The proposed amendment modifies the circuitry that initiates high-head safety injection by adding a new permissive, cold leg injection permissive (P-15). This permissive prevents opening of the high-head safety injection valves until reactor coolant s'ystem pressure decreases to the P-15 set point.

The U.S. Nuclear Regulatory Commission staff has determined that additional information is necessary to complete its review. The request for additional information is enclosed. The licensee agreed to provide answers to the request for additional information within 45 days of the date of this letter.

If you have questions, you can contact me at 301-415-3100 or bye-mail at John. Lamb@nrc.gov.

'~u John . Lamb, Senior Project Manager Pia Licensing Branch 1-2 Divi ion of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST 12-04 APPLICATION REGARDING COLD LEG INJECTION PERMISSIVE NEXTERA ENERGY SEABROOK. LLC.

SEABROOK STATION. UNIT NO.1 DOCKET NO. 50-443 By letter dated March 13, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13079A122), NextEra Energy Seabrook, LLC (NextEra) submitted license amendment request (LAR) 12-04 for Seabrook Station, Unit No. 1 (Seabrook). The proposed change is to the Seabrook Technical Specifications (TSs). The proposed amendment modifies the circuitry that initiates high-head safety injection by adding a new permissive, cold leg injection permissive (P-15). This permissive prevents opening of the high-head safety injection valves until reactor coolant system pressure decreases to the P-15 set point.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is necessary to complete its review.

REQUEST FOR ADDITIONAL INFORMATION (RAI)

The following four RAls (1 through 4) support the evaluation of the independence of redundant equipment and components from the sensor to the actuating device.

1. Clarify whether the LAR's simplified P-15 cold leg injection permissive (CLIP) logic diagram (ADAMS Accession No. ML13079A122, Attachment 1, Figure 1, Page 5) shows the solid state protection system (SSPS) coincidence logic for only one SSPS train, which is duplicated for the other SSPS train, or does it show the SSPS coincidence logic of both SSPS trains.

2. Demonstrate the post-modification allocation of P-15 functions and S-signal functions among the equipment and components related to the P-15 function (e.g., SSPS components, cabinets, channels, trains, actuated devices and the electrical division/separation group associated with each, etc.).

3. Regarding the "two relays with contacts in series with an S-signal relay" (ADAMS Accession No. ML13079A122, Attachment 1, Page 4):

a. Clarify whether these two relays are in series or are in parallel with one another prior to being in series with an S-signal relay;

b. Clarify whether there are two relays (Le. redundant relays) within each SSPS train, or one-relay in one SSPS train, and another relay in the other SSPS train;

c. Provide the location(s)/cabinets(s) where the series connections between these two relays and the S-signal relay(s) is/are made;

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d. Clarify whether each SSPS train affects the S-signal relays for both cold leg injection valves (1-SI-V-138 and 1-SI-V-139), or only a single cold leg injection valve that is associated with one of the two SSPS trains.

4. For the equipment affected by this proposed modification, identify each electrical isolation point between otherwise independent redundant channels (SSPS input cabinets) and trains (SSPS logic cabinets), along with any non-safety equipment, and demonstrate that the electrical isolation is adequate for independence between redundant portions of the safety system, and between safety and non-safety equipment (Le., demonstrate how the Institute of Electrical and Electronics Engineers (IEEE) Std 603-1991, "Criteria for Safety Systems for Nuclear Power Generating Stations," Clauses 5.6.1 and 5.6.3, along with General Design Criterion 22, "Protection System Independence," are satisfied). This information should address all monitoring points and indication, including any that the simplified P-15 logic diagram depicts, if applicable (ADAMS Accession No. ML13079A122, Attachment 1, Figure 1, Page 5).

The following three RAls (5 through 7) support the evaluation of continued compliance to the plant's design basis, as applicable to the modified equipment.

5. Identify any deviations from the existing SSPS instrumentation design basis, as documented in the Seabrook Updated Final Safety Analysis Report (UFSAR), Revision 12, that is applicable to this modification (e.g., modifications to the SSPS input cabinets or SSPS logic cabinets).

6. Identify and describe testing features associated with the proposed modification with respect to the current SSPS instrumentation design basis that solid-state logic testing checks the digital signal path from the input to the logic matrices (as implemented within the SSPS logic cabinets) to the inputs of the slave relays (see Seabrook UFSAR, Chapter 7, Revision 9, Section 7.3, Page 15) (Le., that demonstrates how IEEE Std 603-1991, Clause 6.5, and the testability portion of General Design Criterion 21, "Protection System Reliability and Testability," are satisfied).

7. Regarding the Bypass Test Instrumentation (BTl) signals (ADAMS Accession No. ML13079A122, Attachment 1, Figure 1, Page 5):

a. Clarify whether their use is consistent with Seabrook UFSAR, Chapter 7, Revision 9, Section 7.3, Page 14, which allows testing of a process channel when in bypass via an active high signal, where there is a unique BTl control for each P-15 process channel's bistable. If not, please provide an explanation of the BTl signal used to control the P-15 process channel bistables;

b. Describe whether and how indication of each new bypass will be provided (Le.,

demonstrate how IEEE Std 603-1991, Clauses 5.8.3, and 6.7, are satisfied).

The following five RAls (8 through 12) support the evaluation of reliability during normal operations and when a channel is in bypass, as applicable to the modified equipment.

8. Clarify whether any bypass capability is provided for the P-15 function coincidence logic in addition to that provided for the P-15 function process channels.

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9. Describe any fail safe behavior of the P-15 function (e.g., the permissive state under complete loss of offsite power, etc.).

10. Describe the reliability of the implementation (e.g., circuits and any programmable device) of the P-15 function that supports the statement, "NextEra concludes that the reliability of the P-15 permissive is commensurate with the safety function performed" (ADAMS Accession No. ML13079A122, Attachment 1, Page 6) (i.e., demonstrate how the P-15 function reliability has been established in accordance with IEEE Std 603-1991, Clause 4.9, and how IEEE Std 603-1991, Clause 5.15 is satisfied).

11. Clarify whether the design-basis exception of IEEE Std 279-1971, Paragraph 4.11, for "the single failure criterion for one-out-of-two systems during channel bypass where acceptable reliability of operation can be demonstrated, as justified by WCAP-1 0271, Supplement 2,"

will be applied to any equipment that performs any portion of the P-15 function (see Seabrook UFSAR, Revision 12, Section 7.2, Page 34). If so, the demonstration of "acceptable reliability of operation" should also be provided.

12. The NRC staff requests additional information that clarifies whether any of the four reactor coolant pressurizer pressure transmitter channels (I-PB 455 H, II-PB 456 H, III-PB 457 H, IV-PB 458 H) are shared by control functions in addition to the P-15 function (Le.,

demonstrate that General Design Criterion 24, "Separation of Protection and Control Systems," is satisfied beyond the electrical separation provided by isolators, as discussed in Seabrook UFSAR, Revision 12, Section 7.1.2.2a, Page 14).

The following RAI (13) supports the evaluation of the P-15 setpoint for reliable operation of the P-15 function.

13. Regarding the evaluation of the P-15 setpoint and its allowable values under increasing and decreasing pressurizer pressure (see marked up TS, Table 3.3-4, FUNCTIONAL UNIT 10.d):

a. Provide a representative calculation of the setpoint methodology used to establish the allowable values of nominal permissive set/reset points for P-15 and the limiting acceptable values for the as-found and as-left tolerances, as measured during periodic surveillance testing;

b. Identify any related analytical limit or other limiting design value for the P-15 setpoint along with the source of the limit(s);

c. Provide a summary description that addresses each of the following, consistent with Regulatory Issue Summary 2006-17, "NRC Staff Position on the Requirements of 10 CFR 50.36, 'Technical Specifications,' Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels," for the P-15 function:

L the channel performance data that has been used to establish the value of the limiting permissive setpoint (Le., least conservative as-left value associated with the nominal permissive setpoint);

iL the channel performance data that has been used to establish the values of the as-found and as-left tolerances;

-4 iii. representative pressurizer pressure signal conversion and circuit error performance data that has been (or will be) used within the calculation, to demonstrate that the analysis of this data for each P-15 channel meets the acceptance criteria of 95/95 for the performance of the P-15 function (see Regulatory Guide 1.105, "Instrument Setpoints for Safety-Related Systems,"

Position 1);

iv. how the channel performance data is used to establish the nominal permissive setpoint and its associated as-left and as-found tolerances.

June 28, 2013 Mr. Kevin Walsh, Site Vice President c/o Michael O'Keefe Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT NO. 1- REQUEST FOR ADDITIONAL INFORMATION FOR LICENSE AMENDMENT REQUEST 12-04, APPLICATION REGARDING COLD LEG INJECTION PERMISSIVE (TAC NO. MF1158)

Dear Mr. Walsh:

By letter dated March 13, 2013 (Agencywide Documents Access and Management System Accession No. ML13079A122), NextEra Energy Seabrook, LLC (licensee) submitted license amendment request 12-04 for Seabrook Station, Unit No.1 (Seabrook). The proposed change is to the Seabrook Technical Specifications. The proposed amendment modifies the circuitry that initiates high-head safety injection by adding a new permissive, cold leg injection permissive (P-15). This permissive prevents opening of the high-head safety injection valves until reactor coolant system pressure decreases to the P-15 set point.

The U.S. Nuclear Regulatory Commission staff has determined that additional information is necessary to complete its review. The request for additional information is enclosed. The licensee agreed to provide answers to the request for additional information within 45 days of the date of this letter.

If you have questions, you can contact me at 301415-3100 or bye-mail at John. Lamb@nrc.gov.

Sincerely, Ira!

John G. Lamb, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosure:

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