ML20129B821

Application for Amend to License NPF-86,consisting of Change Request 96-02,proposing Changes That Involve Relocation of Four TS Re Instrumentation Requirements Contained in TS Section 3/4.3

ML20129B821
Person / Time
Site:	Seabrook
Issue date:	10/17/1996
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
Shared Package
ML20129B818	List: ML20129B814 ML20129B821 ML20129B836
References
TAC-M96723, NUDOCS 9610230123
Download: ML20129B821 (11)

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l This License Amendment Request is submitted by North Atlantic Energy Service Corporation i pursuant to 10CFR50.90. The following infonnation is enclosed in support of this License Amendment Request:

. Section I -

Introduction and Safety Assessment for Proposed Changes e Section 11 -

Markup of Proposed Changes e Section lli -

Retype of Proposed Changes

. Section IV -

Determination of Significant Hazards for Proposed Changes  ;

• Section V -

Proposed Schedule for License Amendment issuance and Effectiveness

. Section VI -

Environmentallmpact Assessment Sworn and Subscribed befpre me this ~ f W l day of w0 W .199s y[ d d f nbW Ted C. Feigenbauffi y Notary Public Executive Vice President and Chief Nuclear Officer 9610230123 961017 PDR ADOCK 05000443 P PDR

l THE FOLLOWING INFORMATION IS PROVIDED IN SUPPORT OF LICENSE AMENDMENT REQUEST- LAR 96-02:

1. INTRODUCTION AND SAFETY ASSESSMENT OF PROPOSED CHANGES Refer to the enclosed introduction and safety assessment of the proposed changes to the Technical Specifications addressed by this license amendment request.

l II. MARKUP OF PROPOSED CHANGES Refer to the attached markup of the proposed changes to the Technical Specifi:ations. The attached markup reflects the currently issued revision of the Technical Specifications listed below. Pending Technical Specifications or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed markup.

The following Technical Specifications are to be relocated to the Technical Requirements Manual see attached mark-ups:

Technical Specification Title Page(s)

LCO - 3.3.3.2 Incore Detector System 3/4 3-40 LCO - 3.3.3.3 and associated SRs & Tables Seismic Instrumentation 3/4 3-41,42&43 LCO - 3.3.3.4 and associated SRs & Tables Meteorological Instrumentation 3/4 3-44&45 LCO - 3.3.4 and associated SRs Turbine Overspeed Protection 3/4 3-67 Note: The associated Bases for the aforementioned technical specifications will be deleted and will not be incorporated into the Technical Requirements Manual. In addition, reference to meteorological tower location in TS 5.5, " Meteorological Tower Location" ( page 5-9), will be deleted and will not be incorporated into the Technical Requirements Manual. The location for the meteorological tower is shown Figures 1.2-land 2.3-9 of the Seabrook Station Updated Final Safety Analysis Report. TS Figure 5.1-1," Site and Exclusion Area Boundary"(page 5-3), will not be relocated or altered.

III. RETYPE OF PROPOSED CHANGES Refer to the attached retype of the proposed changes to the Technical Specifications. The attached retype reflects the currently issued version of the Technical Specifications. Pending Technical Specification changes or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed retype. The enclosed retype should be checked for continuity with Technical Specifications prior to issuance.

IV. DETERMINATION OF SIGNIFICANT HAZARDS FOR PROPOSED CHANGES Refer to the enclosed determination of significant hazards for the proposed changes to the Technical Specifications addressed by this license amendment request.

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V. PROPOSED SCHEDULE FOR LICENSE AMENDMENT ISSUANCE AND EFFECTIVENESS North Atlantic requests NRC review of License Amendment Request 96-02 and issuance of a license amendment by February 28,1997 having immediate efTectiveness and implementation required with n 60 days. Issuance of this license amendment by the requested date will allow the relocation of the Technical Specifications listed in Section 11 above to the Seabrook Station Technical Requirements Manual, a licensee-controlled document. The proposed schedule will allow North Atlantic to immediately start implementation of seismic instrumentation upgrade and eliminate the scheduled (beginning in March 1997) calibration of the presently installed seism!c instrumentation that is to be replaced. Issuance of the license amendment prior to March 1997 wih relieve North Atlantic of the burden and expense of calibrating seismic instrumentation soon to be to replaced.

VI. ENVIRONMENTAL IMPACT ASSESSMENT North Atlantic has reviewed the proposed license amendment against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increase the types and amounts of effluent that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, North Atlantic concludes that the proposed change meets the criteria delineated in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement 2

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Section I Introduction and Safety Assessment for the Proposed Changes 3

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L INTRODUCTION AND SAFETY ASSESSMENT OF PROPOSED CHANGES A. Introduction License Amendment Request (LAR) 96-02 proposes the relocation of four instrumentation-related i Limiting Conditions for Operation (LCOs) contained in Technical Specification (TS) Section 3/4.3, ,

" Instrumentation", to the Seabrook Station Technical Requirements Manual (SSTR). They are:

LCO 3.3.3.2 - Incore Detector System LCO 3.3.3.3 - Seismic Instrumentation LCO 3.3.3.4 - Meteorological Instrumentation LCO 3.3.4 - Turbine Overspeed Protection The relocation of the aforementioned LCOs along with their associated surveillance requirements (SRs) is allowed by NRC Generic . Letter 95-10 and the NRC " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" as discussed below.

NRC Generic Letter (GL) 95-10, " Relocation of Selected Technical Specifications Requirements Related to Instrumentation", was issued on December 15, 1995 to all holders of operating licenses and construction permits for nuclear power reactors so that they may request a license amendment to relocate selected instrumentation requirements from their Technical Specifications (TSs). GL 95-10 stated that the NRC had issued a policy statement, " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors"(58 FR 39312), which provided a specific set of four (4) objective criteria to determine which of the design conditions and associated surveillances should be located in the TSs as limiting conditions for operation. GL 95-10 noted that implementation of these additional criteria, as amended to 10 CFR 50.36, may cause some requirements presently in TSs, i particularly those associated with instrumentation, to no longer merit inclusion in TSs. GL 95-10 lists typical instrumentation related TSs as candidates for relocation to licensee-controlled documents. The specific Seabrook Station instrumentation-related TSs proposed by LAR 96-02 for relocation to the SSTP are among those listed in GL 95-10. j The Seabrook Station Technical Requirements Manual (SSTR) is a licensee-controlled document which contains certain technical requirements and is the implementing manual for the Technical Specification Improvement Program referenced in Section 6.7 of the Technical Specifications. Changes to these requirements are reviewed and approved in accordance with Seabrook Station Technical Specifications, Section 6.7, and as outlined in the SSTR. Specifically, all changes to the SSTR require a 10 CFR 50.59 safety evaluation and be reviewed and approved by the Station Operations Review Committee (SORC) and the Nuclear Safety Audit Review Committee (NSARC) prior to implementation.

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B. Safety Assessments of Proposed Changes 1.

LCO 3.3.3.2 -Incore Detector System; The incore Instrumentation System, consisting of fixed and movable incore flux detectors and thermocouples, is used to calculate power peaking factors to verify design predictions, ensure operation within established fuel performance limits, calibrate the Excore Neutron Flux Detection System and provide input to the Fixed Incore Detector System Alarm and the Inadequate Core Cooling Monitoring System. The system consists of 58 thimble assemblies, each containing five axially spaced fixed detectors, one thermocouple and a calibration tube for the movable neutron detector, each thimble assembly being at a fixed core locetion within the center of selected fuel assemblies. The number and location of these assemblies have been chosen to permit measurement of local to average peaking factors to an acceptable accuracy.

The Movable Incoic betector System (MIDS) uses six (6) movable miniature neutron detectors which can traverse the center of the selected fuel assemblies and be positioned anywhere along the length of the fuel assembly vertical axis to obtain axial flux distribution data along the center of a fuel assembly The Fixed Incore Detector System (FIDS) provides continuous flux distribution signals which are processed by the Fixed Incore Detector Data Acquisition System (FIDDAS) which acquires and stores the FIDS data on the main plant computer every na ate. A FIDS Alarm is derived from the main plant computer fixed incore detector monitor program (FIDMON) which processes the FIDS data every minute by comparing the individual fixed incore detector signals with detector specific setpoints to produce the FIDS Alarm. The FIDS Alarm provides assurance that the Heat Flux Hot Channel Factor limit, as specified in TS 3.2.2, is not exceeded during normal operation or in the event of transient power distributions. This assures that the initial conditions assumed for the LOCA analysis are met and the consequences of a LOCA would be within specified acceptance criteria. To assure that the FIDS Alarm setpoint does not exceed die Heat Flux Hot Channel Factor limit defined in TS 3.2.2 surveillance requirement (SR) 4.2.2.2 requires the FIDS Alarm setpoint to be updated with the latest available power distribution at least once per 31 EFPD.

The FIDS and MIDS are both available for use in power distribution analysis but only the FIDS is used in developing the FIDS Alarm. Flux data obtained from either the fixed incore detectors or movable detectors and in conjunction with analytical predictions of the fluxes can be used to infer an incore three-dimensional power distribution. Once the power distribution is inferred, the maximum local power peaking and hot channel factors (Heat Flux Hot Channel Factor and Enthalpy Rise Hot Channel Factor) and incore axial flux difference (AFD) can be derived and compared to established limits. In addition, incore flux data is used to periodically calibrate the Excore Neutron Flux Detection System and the FIDS and MIDS may be used for rod position verification and be used to confirm quadrant power tilt ratio (QPTR).

The incore thermocouples provide continuous information for monitoring fuel assembly exit temperatures in determining core temperature distribution and for use as part of the Inadequate Core Cooling Monitoring System (which calculates core sub-cooling margin and provides an approximate indication of the relative void content of the circulating fluid). The incore thermocouples are not subject to the Limiting Conditions for Operation or Surveillance I

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Requirements of TS 333.2,"Incore Detector System", and therefore not part of this LAR. The incore thermocouples are subject to the requirements of TS 333.6," Accident Monitoring" The instrumentation which comprise the Incore Instrumentation System do not provide signals to any control devices / systems and do not provide direct input to the reactor protection system or engineered safety features actuation system function. These instruments are neither used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary, nor do they function as a primary success path to mitigate events which assume a failure of or a challenge to the integrity of fission product barriers. Although the core power distributions (measured by the incore detectors) constitute an important initial condition to  ;

design basis accidents, the detectors themselves are not an active design feature needed to i preclude analyzed accidents or transients. The measurements from the incore detectors are used in a confirmatory manner. Core power distribution limits are addressed, and will continue to be addressed, in TS Section 3/4.2, " Power Distribution Limits" The present TS 333.2 ACTION for Incore Detector System inoperability is not to use the system for monitoring or calibration functions. This will continue to be the case when TS 333.2 is relocated to the Technical Requirements Manual. Additionally, the provisions'of TS 3.03 are not applicable to TS 333.2.

Thus, the inoperability of this system does not require a change to the plant operating condition.

Where operation is dependent on the FIDS Alarm being OPERABLE and should FIDS Alarm inoperability occur, again other TS 3/4.2 Section LCOs and corresponding ACTIONS provide instruction for FIDS Alarm inoperability.

Based on the foregoing assessment of the Seabrook Station specific Incore Detector System, North Atlantic agrees with the NRC staff conclusion, as stated in GL 95-10, that the incore detector requirements do not meet the criteria of 10 CFR 5036 for inclusion in TSs and can be relocated to a licensee-controlled document, i.e. Seabrook Station Technical Requirements Manual.

2. LCO 33.33 - Seismic Instrumentation; The Seismic Monitocing (SM) Sy tem provides information concerning the response of Seismic Category I equipment (systems, structures and components) and other plant features important to safety to a seismic event. This information is compared to calculated design values to determine whether the design value has been exceeded in order to detennine if the plant can continue to be operated safely.

The selection and function of the various instruments employed by the SM system were based on the safe shutdown eanhquake (SSE) and operating basis earthquake (OBE) limits for Seabrook Station. These instruments determine whether a seismic design condition has been exceeded by:

a recording the time history of vibratory motion, e recording the response spectrum, e recording the peak acceleration, and e providing alarms when limits are exceeded.

The seismic monitoring instruments and associated signal processing equipment which constitute the SM system do not provide signals to actuate any protective equipment or serve any direct role in the mitigation of an accident. The SM system is neither used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary, nor does it function as a primary success path to mitigate events which assume a failure of or a challenge to 6

the integrity of fission product barriers. A seismic event may be a precursor to reactor coolant pressure boundary leakage, however as stated earlier, SM instrumentation is incapable of detecting significant abnormal degradation of the reactor coolant pressure boundary. The SM system is used to alert operators to a seismic event and permit timely operator action to promptly determine the magnitude of the seismic event, evaluate plant response of those features important to safety and to take appropriate action to place the plant in a safe condition, if deemed necessary.

Based on the foregoing assessment of the Seabrook Station specinc seismic monitoring instrumentation, North Atlantic agrees with the NRC staff conclusion, as stated in GL 95-10, that the seismic monitoring instrumentation requirements do not meet the criteria of 10 CFR 50.36 for inclusion in TSs and can be relocated to a licensee-controlled document, i.e. Seabrook Station Technical Requirements Manual.

3. LCO 3.3.3.4 - Meteorological Instrumentation; Meteorological monitoring instrumentation provides pertinent meteorological data for estimating potential radiation doses to the public. A knowledge of meteorological conditions in the vicinity of the reactor is important in providing a basis for determining the appropriate protective measures, if any, to be taken to protect the health and safety of the public during a radiological emergency that involves an accidental release or potential release of radioactive materials to the atmosphere.

Meteorological information is used to aid the operator in deciding which makeup air intake to the control room complex should be isolated during emergency conditions that involve hazardous airborne contaminants. Meteorological information is also used for supporting the operation of the Cooling Tower during nermal plant operating conditions and for identifying high winds for initiating Emergency Actico Levels. Routine collection of humidity (dew point) has been discontinued since the infrequent operation of the cooling tower minimizes the potential for fog or ice formation. The data to support operation of the cooling tower duriag normal plant operation is now collected manually through the use of a psychrometer.

A knowledge of local meteorological conditions is also necessary to support information provided in the Annual Radioactive EfHuent Release Report to the NRC, as required by TS 6.8.1.4, that estimates the maximum potential annual radiation doses to the public from authorized routine release ofliquid and airborne radioactive efDuents to unrestricted areas.

The primary meteorological monitoring instrumentation at Seabrook Station consists of instruments mounted on a 210 ft. tower which measure wind speed and direction at various elevations, temperature at various elevations, precipitation and solar radiation. Signals from these instruments are input to the main plant computer system (MPCS) for on-demand display at terminals located in the control room, Technical Support Center (TSC), and Emergency Operations Facility (EOF). All parameters are also recorded for backup purposes on recorders located in the Instrument Building near the tower's base. In addition, a backup to the primary meteorological monitoring instrumentation is provided by an independent instrumented tower which has wind speed and direction sensors mounted at one elevation. Signals from these sensors are also inputted to the MPCS. The entire system is classined o non-safety related containing non-Class 1E equipment and is non-seismically qualiGed.

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The meteorological monitoring instruments do not provide signals to actuate any protective equipment or serve any direct role in the mitigation of an accident. Meteorological instrumentation is neither used for, nor capable of, detecting a significant abnormal degradation of the reactor coolant pressure boundary, nor do they function as a primary success path to mitigate events which assume a failure of or a challenge to the integrity of fission product barriers.

' Meteorological monitoring instrumentation may provide warning of significant meteorological conditions (e.g. high winds, potential flooding) whereby prudent management action would be to place the plant in a safe condition, however, meteorological instrumentation does not serve to ensure that the plant is operated within the bounds of initial conditions assumed in design basis accident and transient analyses or that the plant will be operated to preclude transients or accidents.

Based on the foregoing assessment of the Seabrook Station specific meteorological monitoring instrumentation, North Atlantic agrees with the NRC staff conclusion, as stated in GL 95-10, that the meteorological monitoring instrumentation requirements do not meet the criteria of 10 CFR 50.36 for inclusion in TSs and can be relocated to a licensee-controlled document, i.e. Seabrook Station Technical Requirements Manual.

4. LCO 3.3.4 - Turbine Overspeed Protection; The turbine overspeed protection system is designed to protect the turbine from excessive overspeed. Protection from turbine excessive overspeed is required since excessive overspeed of the main turbine could generate potentially damaging missiles which could impact and damage safety-related systems, structures or components.

Excessive overspeed protection is provided by the main turbine emergency trip system. The emergency trip system is a high-pressure hydraulic fluid system that when pressurized permits opening of all turbine main steam and intermediate valves by the electro-hydraulic system, and, when depressurized, causes them to be rapidly closed by spring action. Upon reaching the overspeed trip setpoint the depressurization of the emergency trip system is actuated by either or both of the following devices:

Mechanical overspeed trip set at 110 percent speed Electrical backup overspeed trip set one-half percent higher than the mechanical overspeed trip.

Surveillance testing & inspection and maintenance programs for the main turbine valves and trip system are outlined in Seabrook Station UFSAR Section 10.2, Safety Evaluation Report (SER)

& Supplements (NUREG-0896) and New llampshire Yankee correspondence to the NRC, "Seabrook Station Turbine Overspeed Protection Maintenance and Testing Program"; NYN-92066, dated May 25,1992.

SER Section 3.5.1.3, Turbine Missiles, noted that neither Unit I or Unit 2 (never completed) main turbine generators can be considered favorably oriented because there are site safety-related structures, systems and components within the low trajectory missile strike zone of each j turbine. Analysis, based on conservative historical turbine failure data probabilities for the generation of missiles from design speed and destructive overspeed failure, as presented in 8

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l l- UFSAR Section 3.5.1.3.d 4 states that the total probability of unacceptable damage to safety-related structures from low trajectory missiles is less than 7.5E-7 per year. The probability of a I high-trajectory missile hit is less than 1E-7 per year for any single structure. It further states that

{ many such missile strikes will not result in unacceptable damage. Furthermore, to ensure the '

integrity of the turbine, and therefore, reduce the possibility of turbine failure, Seabrook Station  ;

j committed to an augmented inservice inspection, maintenance and testing program as noted and i outlined in the aforementioned correspondence NYN-92066. NRC conclusions in SER Section

[ 3.5.1.3 determined that based on its review and agreements the turbine missile risk for Seabrook i Station is acceptable and meets the requirements of GDC 4. i i

j In view of the orientation of the main turbine relative to plant structures and equipment, the low i

probability of unacceptable missile damage to structures and equipment important to safety, the  !

i on-going and augmented surveillance and maintenance programs, and industry operating

[ experience of low failure rates of main turbines due to overspeed events; the consequences of a l

turbine overspeed event which generates missiles that directly leads to failure of plant structures and equipment important to safety is very low. There is low likelihood of significant risk to l i public health and safety because of turbine overspeed events. Failure of plant structures and i j equipment due to missiles strikes are much more likely to be caused by events other than turbine j failures.  !

l Although design basis accidents and accidents include a variety of system failures and conditions  ;

I which might result from missiles striking various plant structures and equipment the turbine j overspeed protection is neither part of an initial condition of a design basis accident or transient

! that either assumes the failure of or presents a challenge to the integrity of a fission product j barrier, nor is it relied upon as a primary success path to mitigate such events.

Based on the foregoing assessment of the Seabrook Station specific turbine overspeed protection j system, North Atlantic agrees with the NRC staff conclusion, as stated in GL 95-10, that the i turbine overspeed protection requirements do not meet the criteria of 10 CFR 50.36 for inclusion j in TSs and can be relocated to a licensee-controlled document, i.e. Seabrook Station Technical

Requirements Manual.

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Section II Markup of Proposed Changes 10

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