ML13338A141

Seabrook Station, Unit 1 - Request for Additional Information for License Amendment Request 13-03, Application for Technical Specification Change Regarding Risk-Informed Justifications for Relocation of Specific Frequency Requirements to a

ML13338A141
Person / Time
Site:	Seabrook
Issue date:	12/11/2013
From:	Lamb J G Plant Licensing Branch 1
To:	Walsh K NextEra Energy Seabrook
Lamb J G
References
TAC MF1958
Download: ML13338A141 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Kevin Walsh, Site Vice President c/o Michael Ossing Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874 December 11, 2013

SUBJECT:

SEABROOK STATION, UNIT 1-REQUEST FOR ADDITIONAL INFORMATION FOR LICENSE AMENDMENT REQUEST 13-03, "APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING RISK-INFORMED JUSTIFICATIONS FOR RELOCATION OF SPECIFIC FREQUENCY REQUIREMENTS TO A LICENSEE-CONTROLLED PROGRAM" (TAC NO. MF1958)

Dear Mr. Walsh:

By letter dated May 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 13155A002), NextEra Energy Seabrook, LLC (NextEra) submitted license amendment request (LAR) 13-03 for Seabrook Station, Unit 1 (Seabrook). The proposed change is to the Seabrook technical specifications (TS). Specifically, the proposed amendment would modify the TS 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 are consistent with U.S. Nuclear Regulatory Commission (NRC)-approved TS Task Force Standard TS change TSTF-425, "Relocate Surveillance Frequencies to Licensee Control-RITSTF [Risk-Informed TS Task Force] Initiative 5b," Revision 3 (ADAMS Accession No. ML090850642). The Federal Register notice published on July 6, 2009 (74 FR 31996), announced the availability of this TS improvement. The NRC staff has determined that additional information is necessary to complete its review. The request for additional information (RAI) is enclosed. A draft of these questions was previously sent to Mr. Gary Kilby of your staff on October 24, 2013, with an opportunity to have a teleconference to ensure that the licensee understood the questions and their regulatory basis, as well as to verify that the information was not previously docketed. A conference call was held on November 25, 2013, and Mr. Kilby agreed that NextEra would respond to the RAI by January 31, 2014. Please note that if you do not respond to the RAI by January 31, 2014, the NRC staff may reject your request for relief under the provisions of Title 1 0 of the Code of Federal Regulations, Section 2.1 08, "Denial of application for failure to supply information."

K. Walsh If you have questions, you can contact me at 301-415-3100 and/or John.Lamb@nrc.gov. Docket No. 50-443

Enclosure:

Request for Additional Information cc w/ enclosure: Distribution via Listserv . J:) . Lamb, Senior reject Manager Pia t icensing Branch 1-2 Divi on of Operating Reactor Licensing Offi e of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST 13-03, APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTSF-425 NEXTERA ENERGY SEABROOK, LLC. SEABROOK STATION, UNIT 1 DOCKET NO. 50-443 By letter dated May 28, 2013 (Reference 1 ), NextEra Energy Seabrook, LLC (NextEra) submitted license amendment request (LAR) 13-03 for Seabrook Station, Unit 1 (Seabrook). The proposed change is to the Seabrook technical specifications (TS). Specifically, the proposed amendment would modify the TS 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 are consistent with U.S. Nuclear Regulatory Commission (NRC)-approved TS Task Force Standard TS change TSTF-425, "Relocate Surveillance Frequencies to Licensee Control -RITSTF [Risk-Informed TS Task Force] Initiative 5b," Revision 3 (Reference 2). The Federal Register notice published on July 6, 2009 (7 4 FR 31996), announced the availability of this TS improvement. The NRC staff has determined that the following additional information is necessary to complete its review. REQUEST FOR ADDITIONAL INFORMATION 1. In Section 2.2 of the submittal, "Optional Changes and Variations," the licensee states in Item 3 that they propose relocation of surveillance frequencies for surveillances not covered by NUREG-1431, "Standard Technical Specifications Westinghouse Plants," and TSTF-425. The licensee further states that these changes will be evaluated using Nuclear Energy Institute (NEI) 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies" (Reference 3). Discuss what approach (risk, bounding, etc.) will be used and the estimated additional impact to risk, if any, these additions present. 2. Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 1, (Reference 4) states that, to demonstrate technical adequacy of the probabilistic risk assessment (PRA), licensees should identify permanent plant changes (such as design or operational practices) that have an impact on those things modeled in the PRA, but have not been incorporated in the baseline PRA model. Please discuss Seabrook's approach to assessing plant changes not yet incorporated into the PRA model for this application. Enclosure 3. The submittal indicates that the internal fire and seismic events portions of the Seabrook PRA have not been subjected to peer reviews or self-assessments. The submittal does not indicate how the PRAs will be utilized (e.g., detailed evaluations, bounding analyses). Please describe, in more detail, how fire and seismic events would be assessed in terms of the NEI 04-10 guidance. If those portions of the PRA are to be used for detailed evaluations such as Step 12 of NEI 04-10, please demonstrate how they are technically adequate in accordance with Regulatory Guide 1.200 (Reference 4). 4. Attachment 1, Section 3.4, "Part 5 Seismic Events," states that the most recent 2005 upgrade to the Seabrook Seismic PRA (SPRA) did not include an update to the seismic hazard curve. The NRC issued Information Notice 2010-18, "Generic Issue [GI] 199, 'Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants,"' on September 2, 2010, to nuclear power plants and independent fuel storage installations. Gl-199 activities are being addressed in the recently issued Title 10 of the Code of Federal Regulations, Part 50, Section 50.54(f) (50.54(f)) letters on items 2.1 and 2.3 of the Japanese Near-Term Task Force recommendations. Please describe how NextEra ensures the Seabrook SPRA is technically adequate prior to completing the demanded seismic risk evaluation. 5. The following questions relate to facts and observations (F&Os) entries in Attachments A and B of the application which identifies gaps to Capability Category II of the American Society of Mechanical Engineers (ASME) PRA standard. a. For F&O HR-G4-1, clarify the use of "time windows" and confirm that NextEra specifies the point in time at which operators are expected to receive relevant indications. b. For F&O HR-G7-1, for multiple human actions in the same accident sequence, confirm that NextEra accounts for the influence of factors that could lead to dependence such as common practices and procedures. c. For F&O LE-C10-01 for LE-C10 and LE-C12, confirm that NextEra conducted the review to achieve Capability Category II and used conservative or a combination of conservative and realistic treatment for non-significant accident progression sequences. 6. Do the failure probabilities of structures, systems, and components that are in standby mode for extended periods, as modeled in the Seabrook PRA, include a standby related contribution and a cyclic demand-related contribution? Please describe how you address the standby time-related contribution for extended surveillances.

REFERENCES 1. Letter from K.T. Walsh (NextEra) to NRC, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program," dated May 28, 2013. (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 13155A002) 2. Technical Specification Task Force (TSTF) Traveler 425, "Relocate Surveillance Frequencies to Licensee Controi-RITSTF [Risk-Informed Technical Specification Task Force] Initiative 5b." (ADAMS Accession No. ML090850642) 3. NEI 04-10, Rev. 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies." (ADAMS Accession No. ML071360456) 4. Regulatory Guide 1.200, Revision 1, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities." (ADAMS Accession No. ML062060184)

K. Walsh If you have questions, you can contact me at 301-415-3100 and/or John.Lamb@nrc.gov. Docket No. 50-443

Enclosure:

Sincerely, Ira/ John G. Lamb, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Request for Additional Information cc w/enclosure: Distribution via Listserv DISTRIBUTION: PUBLIC RidsNrrDoriDpr Resource RidsNrrPMSeabrookResource LPLI-2 R/F RidsNrrDorllpl1-2 Resource RidsNrrLAABaxter Resource RidsAcrsAcnw_MaiiCTR Resource RidsRgn1 Mail Center Resource GNewman, NRR JEvans, NRR ADAMS Accession No* ML13338A141 .. *via memorandum **via email OFFICE LPL1-2/PM LPL 1-2/LA APLAIBC LPL 1-2/BC (A) NAME Jlamb A Baxter** HHamzehee* Jlamb DATE 12/6/1 3 12/06/13 10/08/13 12/11/13 OFFICIAL RECORD COPY