ML14345A288

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Issuance of Amendment Regarding Technical Specifications Task Force Traveler-523, Generic Letter 2008-01, Managing Gas Accumulation Using the Consolidated Line Item Improvement Process
ML14345A288
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 02/06/2015
From: John Lamb
Plant Licensing Branch 1
To: Dean Curtland
NextEra Energy Seabrook
John Lamb, NRR/DORL 415-3100
References
GL-08-001, TAC MF4307
Download: ML14345A288 (19)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 6, 2015 Mr. Dean Curtland, Site Vice President clo Michael Ossing Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT REGARDING TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)

TRAVELER-523, "GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION" USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MF4307)

Dear Mr. Curtland:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 144 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 June 24, 2014, as supplemented by letter dated December 11, 2014.

The amendment modifies Seabrook's TS to address NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems." The changes are consistent with the NRG-approved Technical Specifications Task Force (TSTF) Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," for plant-specific adoption using the Consolidated Line Item Improvement Process (CLllP). The Federal Register notice published on January 15, 2014 (79 FR 2700), announced the availability of this TS improvement.

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

rely,. P/~4

.Laml'~Pr"~

Licensing Branch 1-2 ion of Operating Reactor Licensing of Nuclear Reactor Regulation Docket No. 50-443

Enclosures:

1. Amendment No. 144 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. 144 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 June 24, 2014, as supplemented by letter dated December 11, 2014, 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. 144, 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 Meena Khanna, 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: February 6, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 144 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 3/4 4-5 3/4 4-5 3/4 4-6 3/4 4-6 3/4 4-7 3/4 4-7 3/4 5-5 3/4 5-5 3/4 6-14 3/4 6-14 3/4 9-8 3/4 9-8 3/4 9-9 3/4 9-9

(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. 144*, 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. 144

REACTOR COOLANT SYSTEM REACTOR COOLANT LOOPS AND COOLANT CIRCULATION HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required reactor coolant pump(s), if not in operation, shall be determined OPERABLE in accordance with the Surveillance Frequency Control Program by verifying correct breaker alignments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying secondary-side water level to be greater than or equal to 14% in accordance with the Surveillance Frequency Control Program.

4.4.1.3.3 At least one reactor coolant or RHR loop shall be verified in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.3.4 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

SEABROOK - UNIT 1 3/4 4-5 Amendment No. 444, 144

REACTOR COOLANT SYSTEM REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation*, and either:

a. One additional RHR loop shall be OPERABLE**, or
b. The secondary-side water level of at least two steam generators shall be greater than 14%.

APPLICABILITY: MODE 5 with reactor coolant loops filled***.

ACTION:

a. With one of the RHR loops inoperable and with less than the required steam generator water level, immediately initiate corrective action to return the inoperable RHR loop to OPERABLE status or restore the required steam generator water level as soon as possible.
b. With no RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required RHR loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shall be determined to be within limits in accordance with the Surveillance Frequency Control Program.

4.4.1.4.1.2 At least one RHR loop shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.4.1.3 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

  • The RHR pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided: (1) no operations are permitted that would cause dilution of the Reactor Coolant System boron concentration and (2) core outlet temperature is maintained at least 10°F below saturation temperature.
    • one RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop is OPERABLE and in operation.

SEABROOK - UNIT 1 3/4 4-6 Amendment No. 4-#, 144

REACTOR COOLANT SYSTEM REACTOR COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN - LOOPS NOT FILLED LIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two residual heat removal (RHR) loops shall be OPERABLE* and at least one RHR loop shall be in operation.**

APPLICABILITY: MODE 5 with reactor coolant loops not filled.

ACTION:

a. With less than the above required RHR loops OPERABLE, immediately initiate corrective action to return the required RHR loops to OPERABLE status as soon as possible.
b. With no RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required RHR loop to operation.

SURVEILLANCE RQUIREMENTS 4.4.1.4.2 At least one RHR loop shall be determined to be in operation and circulating reactor coolant in accordance with the Surveillance Frequency Control Program.

4.4.1.4.2.1 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

  • one RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop is OPERABLE and in operation.
    • The RHR pump may be deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided: (1) no operations are permitted that would cause dilution of the Reactor Coolant System boron concentration and (2) core outlet temperature is maintained at least 10°F below saturation temperature.

SEABROOK - UNIT 1 3/4 4-7 Amendment No.~. 144

EMERGENCY CORE COOLING SYSTEMS ECCS SUBSYSTEMS - Teyg GREATER THAN OR EQUAL TO 350°F SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position Sl-V-3 Accumulator Isolation Open*

Sl-V-17 Accumulator Isolation Open*

Sl-V-32 Accumulator Isolation Open*

Sl-V-47 Accumulator Isolation Open*

Sl-V-114 SI Pump to Cold-Leg Isolation Open RH-V-14 RHR Pump to Cold-Leg Isolation Open RH-V-26 RHR Pump to Cold-Leg Isolation Open RH-V-32 RHR to Hot-Leg Isolation Closed RH-V-70 RHR to Hot-Leg Isolation Closed Sl-V-77 SI to Hot-Leg Isolation Closed Sl-V-102 SI to Hot-Leg Isolation Closed

b. In accordance with the Surveillance Frequency Control Program by:
1) Verifying ECCS locations susceptible to gas accumulation are sufficiently filled with water, and
2) Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.**
c. By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:
1) For all accessible areas of the containment prior to establishing primary CONTAINMENT INTEGRITY, and
2) At least once daily of the areas affected within containment by containment entry and during the final entry when primary CONTAINMENT INTEGRITY is established.
  • Pressurizer pressure above 1000 psig.
    • Not required to be met for system vent flow paths opened under administrative control.
  • I SEABROOK- UNIT 1 3/4 5-5 Amendment No. 30, 58, 61, 141, 144

CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.1 Two independent Containment Spray Systems shall be OPERABLE with each Spray System capable of taking suction from the RWST* and automatically transferring suction to the containment sump.

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

ACTION:

With one Containment Spray System inoperable, restore the inoperable Spray System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 />; restore the inoperable Spray System to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be 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 4.6.2.1 Each Containment Spray System shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by:
1) Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position is in its correct position**, and
2) Verifying Containment Spray locations susceptible to gas accumulation are sufficiently filled with water.
b. By verifying OPERABILITY of each pump when tested pursuant to Specification 4.0.5;
c. In accordance with the Surveillance Frequency Control Program during shutdown, by:
1) Verifying that each automatic valve in the flow path actuates to its correct position on a Containment Pressure-Hi-3 test signal, and
2) Verifying that each spray pump starts automatically on a Containment Pressure-Hi-3 test signal.
d. By verifying each spray nozzle is unobstructed following activities that could result in nozzle blockage.
  • In MODE 4, when the Residual Heat Removal System is in operation, an OPERABLE flow path is one that is capable of taking suction from the refueling water storage tank upon being manually realigned.
    • Not required to be met for system vent flow paths opened under administrative control.

SEABROOK- UNIT 1 3/4 6-14 Amendment No. 30, 90, 128, 141, 144

REFUELING OPERATIONS 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation.*

APPLICABILITY: MODE 6, when the water level above the top of the reactor vessel flange is greater than or equal to 23 feet.

ACTION:

With no RHR loop OPERABLE and in operation, suspend all operations involving an increase in the reactor decay heat load or a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required RHR loop to OPERABLE and operating status as soon as possible. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.9.8.1 At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2750 gpm in accordance with the Surveillance Frequency Control Program.

4.9.8.1.1 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

  • The RHR loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour period during the performance of CORE ALTERATIONS in the vicinity of the reactor vessel hot legs.

SEABROOK - UNIT 1 3/4 9-8 Amendment No. 444, 144

REFUELING OPERATIONS RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent residual heat removal (RHR) loops shall be OPERABLE, and at least one RHR loop shall be in operation.*

APPLICABILITY: MODE 6, when the water level above the top of the reactor vessel flange is less than 23 feet.

ACTION:

a. With less than the required RHR loops OPERABLE, immediately initiate corrective action to return the required RHR loops to OPERABLE status, or to establish greater than or equal to 23 feet of water above the reactor vessel flange, as soon as possible.
b. With no RHR loop in operation, suspend all operations involving a reduction in boron concentration of the Reactor Coolant System and immediately initiate corrective action to return the required RHR loop to operation. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.9.8.2 At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2750 gpm in accordance with the Surveillance Frequency Control Program.

4.9.8.2.1 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water in accordance with the Surveillance Frequency Control Program.

  • Prior to initial criticality, the RHR loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour period during the performance of CORE ALTERATIONS in the vicinity of the reactor vessel hot legs.

SEABROOK- UNIT 1 3/4 9-9 Amendment No. -M-1-, 144

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 144 TO FACILITY OPERATING LICENSE NO. NPF-86 SEABROOK STATION, UNIT NO. 1 DOCKET NO. S0-443

1.0 INTRODUCTION

By letter dated June 24, 2014, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 14177AS03), as supplemented by letter dated December 11, 2014, (ADAMS Accession No. ML14349A646), 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 adopt U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-S23, Rev1s1on 2, "Generic Letter 2008-01, Managing Gas Accumulation, dated February 21, 2013 (ADAMS Accession No. ML 130S3A07S). The supplement dated December 11, 2014, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on September 2, 2014 (79 FR S2066).

By letter dated July 24, 2014, (ADAMS Accession No. ML13212A069) the NRC issued Amendment No. 141 to Facility Operating License No. NPF-86 for Seabrook, which modified Seabrook's 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 Sb, Risk-Informed Method for Control of Surveillance Frequencies." The changes were consistent with NRG-approved TSTF-42S, "Relocate Surveillance Frequencies to Licensee Controlled [Risk Informed Technical Specifications Task Force] RITSTF Initiative Sb,"

Revision 3. It is noted that Seabrook has a Surveillance Frequency Control Program (SFCP).

The proposed change would revise the surveillance requirements (SRs) related to gas accumulation for the emergency core cooling system (ECCS). The proposed change would also add new SRs related to gas accumulation for the residual heat removal (RHR), and containment spray (CS) systems.

The licensee stated that the license amendment request (LAA) is consistent with NRG-approved Traveler TSTF-523. The availability of this TS improvement was announced in the Federal Register on January 15, 2014 (79 FR 2700) as part of the consolidated line item improvement process (CLllP).

2.0 REGULATORY EVALUATION

2.1 Background Gas accumulation in reactor systems can result in water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel. These effects may result in the subject system being unable to perform its specified safety function. The NRC issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," in January 2008 to address the issue of gas accumulation in ECCS, AHR, and CS systems (ADAMS Accession No. ML072910759). The industry and NRC staff agreed that a change to the STS and plant-specific TS would be necessary to address some of the issues discussed in GL 2008-01. TSTF-523 contains changes to the TS SRs and TS Bases to address some of the concerns in GL 2008-01. The licensee proposed amending the Seabrook TS using a plant-specific adoption of the TSTF-523 changes.

2.2 Technical Specification Changes Changes were proposed for Seabrook TS 3/4.4.1.3, Reactor Coolant Loops and Coolant Circulation - Hot Shutdown;" TS 3/4.4.1.4.1, "Reactor Coolant Loops and Coolant Circulation -

Cold Shutdown - Loops Filled;" TS 3/4.4.1.4.2, "Reactor Coolant Loops and Coolant Circulation

- Cold Shutdown - Loops Not Filled;" TS 3/4.5.2, ECCS Subsystems - T avg greater than or Equal to 350 °F;" TS 3/4.6.2.1, "Containment Systems - Depressurization and Cooling Systems;" TS 3/4.9.8.1, "Residual Heat Removal and Coolant Circulation - High Water Level;"

and TS 3/4.9.8.2, "Residual Heat Removal and Coolant Circulation - Low Water Level."

2.3 Regulatory Review The regulations in Appendix A to Title 1O of the Code of Federal Regulations (1 O CFR) Part 50 or similar plant-specific principal design criteria provide design requirements. Appendix B to 1O CFR Part 50, the TSs, and the licensee quality assurance programs provide operating requirements. The regulatory requirements of 1O CFR Part 50, Appendix A, that are applicable to gas management in the subject systems include: General Design Criteria (GDC) 1, 34, 35, 36, 37, 38, 39 and 40. GDC 1 requires that the subject systems be designed, fabricated, erected, and tested to quality standards. GDC 34 requires an AHR system designed to maintain specified acceptable fuel design limits and to meet design conditions that are not exceeded if a single failure occurs and specified electrical power systems fail. GDC 35, 36, and 37 require an ECCS design that meets performance, inspection, and testing requirements.

Additionally, the regulations in 10 CFR 50.46 provide specified ECCS performance criteria.

GDC 38, 39, and 40 require a containment heat removal system design that meets performance, inspection, and testing requirements.

Quality assurance criteria, as provided in 1O CFR Part 50, Appendix B, that apply to gas management in the subject systems include: Criteria Ill, V, XI, XVI, and XVII. Criteria Ill and V require measures to ensure that applicable regulatory requirements and the design basis, as

defined in 10 CFR 50.2, "Definitions," and as specified in the license application, are correctly translated into controlled specifications, drawings, procedures, and instructions. Criterion XI requires a test program to ensure that the subject systems will perform satisfactorily in service and requires that test results shall be documented and evaluated to ensure that test requirements have been satisfied. Criterion XVI requires measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected, and that significant conditions adverse to quality are documented and reported to management.

Criterion XVII requires maintenance of records of activities affecting quality.

The NRC's regulatory requirements related to the content of the TSs are contained in 1O CFR 50.36(c). The regulations at 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. Typically, TS Section 5 requires that licensees establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operation)." Appendix A to RG 1.33 identifies instructions for filling and venting the ECCS and RHR system, as well as for draining and refilling heat exchangers. Standard TSs and most licensee TSs include SRs to verify that at least some of the subject systems piping is filled with water.

The NRC's guidance for the format and content of licensee TSs can be found in NUREG-1431, "Standard Technical Specifications Westinghouse Plants."

Regulatory guidance for the NRC staff's review of containment heat removal systems, ECCS, and RHR systems, is provided in the following revisions and sections of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR Edition" (SRP).

  • Revision 3 of SRP, Section 6.2.2, "Containment Heat Removal Systems," dated March 2007 (ADAMS Accession No. ML070160661 ), provides the procedures concerning the review of containment heat removal under post-accident conditions to ensure compliance with GDC 38, 39, and 40.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensee's proposed change against the applicable regulatory guidance in the STS, as modified by TSTF-523. The proposed change adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1431, "Standard Technical Specifications Westinghouse Plants," by TSTF-523. The Seabrook TS utilizes different numbering, format, and titles than NUREG-1431 on which TSTF-523 was based. The NRC staff found that the proposed changes are consistent with guidance in the STS, as modified by TSTF-523, and the differences do not affect the applicability of TSTF-523 to Seabrook.

The NRC staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 1o CFR 50.36.

The licensee proposed the following TS changes:

(1) Add SR 4.4.1.3.4, which states, "Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water" with a note that states "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4" and a frequency of in accordance with the SFCP, (2) Add SR 4.4.1.4.1.3, which states, "Verify required AHR loop locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of in accordance with the SFCP, (3) Add SR 4.4.1.4.2.1, which states, "Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of in accordance with the SFCP, (4) Add a note to SR 4.5.2, which states, "Not required to be met for system vent flow paths opened under administrative control,"

(5) Revise the language for SR 4.5.2 from "Verify ECCS piping is full of water" to "Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water,"

(6) Add a note to SR 4.6.2.1, which states, "Not required to be met for system vent flow paths opened under administrative control,"

(7) Add SR 4.6.2.1, which states, "Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of in accordance with the SFCP, (8) Add SR 4.9.8.1, which states, "Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water" with a frequency in accordance with the SFCP,

(9) Add SR 4.9.8.2, which states, "Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water" with a frequency in accordance with the SFCP, (10) Add and revise the affected TS SR Bases language to state the purpose of the SR, discuss methods of identifying locations susceptible to gas accumulation, discuss gas volume acceptance criteria, discuss methods for performing the SR, consistent with licensee actions and on-going programs related to GL 2008-01, and describe the SR frequency, and (11) Add and revise TS Limiting Condition of Operation (LCO) Bases language to describe what is required for Operability of the systems and reiterate the importance of gas management.

The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRG discussion contained in Task Interface Agreement {TIA) 2008-03, "Emergency Core Cooling System (ECCS) Voiding Relative To Compliance With Surveillance Requirements (SRs) 3.5.1.1, 3.5.2.3, and 3.5.3.1" (ADAMS Accession No. ML082560209). Many of the GL 2008-01 responses stated that licensees identified system locations susceptible to gas accumulation. In the TIA, the NRG stated that the intent of the TS SRs, which state full of water," may be met if the licensee can establish, through an Operability Determination, that there is a reasonable expectation that the system in question will perform its specified safety function. Therefore the phrase, "sufficiently filled with water" was recommended for the proposed TS changes. In the TS, "sufficiently filled with water" is understood to mean "sufficiently filled with water to support Operability." The regulation at 1O CFR 50.36(c)(3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the new SR language, "Verify the [system name] locations susceptible to gas accumulation are sufficiently filled with water," is acceptable since this language will allow the licensee to make a conclusion as to whether or not a system is operable.

The language for the notes that state that the SR does not have to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Mode 4 for pressurized water reactors is acceptable because the note provides a limited time to perform the Surveillance after entering the Applicability of the LCO; however, under the STS usage rules (STS Section 1.4), the requirement to manage gas accumulation is not affected. Licensees must have confidence that the SR can be met or the LCO must be declared as not met.

The language for the notes that allow the SRs to not be met for the system vent flow paths opened under the administrative control is necessary. This is necessary in order to allow the licensee to credit administratively controlled manual action to close the system vent flow path to maintain system Operability during system venting and performance of the proposed gas accumulation SR. Therefore these notes are acceptable.

The NRG staff found that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCOs will be met. Therefore, the NRG staff finds the proposed change acceptable.

The regulation at 10 CFR 50.36(a)(1) states, in part, that: "A summary statement of the bases or reasons for such specifications ... shall also be included in the application, but shall not become part of the technical specifications." Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes corresponding to the proposed TS changes. The NRC staff determined that TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors dated July 22, 1993 (58 FR 39132).

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 or 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 2, 2014 (79 FR 52066). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 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 Contributor: John G. Lamb Date: February 6, 2015

  • .. ML14345A288 *via email OFFICE LPL 1-2/PM LPL 1-2/LA STSB/BC OGC - NLO LPL 1-2/BC LPL 1-2/PM NAME JLamb A Baxter RElliott DRoth MKhanna JLamb DATE 01/23/2015 02/02/2015 01/21/2015 01/03/2015 02/03/2015 2/6/2015
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