ML20198E778
| ML20198E778 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/16/1998 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | |
| Shared Package | |
| ML20198E775 | List: |
| References | |
| NUDOCS 9812240143 | |
| Download: ML20198E778 (8) | |
Text
._. .- - _ - . . .-. . ._ _ _ . .. - .
s, 4
'"'N North Atlantic SEABROOK STATION UNIT 1 g i W aj ,y,e gjgy6p,ratingIJcensdNPF46 .
I ir 1
^'
~ ' : DwksNo.50-443 -
' Jf:0 yf
^
- f_' [
j' q
- -LICENSE AMENDMENT REQUEST 9849,P s
- 1 ,
w' . 1 N_fEDIT RIAI) AND" ADMIN. ISTRATIV. E CHAN.GES T. O,TECHN.ICAL;g SPECIFICl
.3- ,.
- j. (l. 4, ,Yf;" < US) t
> l
- s o l ,
3; This License Amendment Request is submitted by North Atlantic Energy Service Corporation pursuant to 10CFR50.90. The following information is enclosed in support of this License Amendment Request:
- Section1 -
Introduction and Safety Assessmentfor Proposed Change
- Section 11 -
Markup of Proposed Change
- Sectionll1 -
Retype of Proposed Change
- Sec' ion IV -
Determinationof SignificantHazardsfor ProposedChange
- Section V - Proposed Schedule for License Amendmentissuance and Effectiveness
- Section VI - Environmentallmpact Assessment Sworn and Subscribed da f bk .1998 [
?ddfV/h' W//
Ut,',
'Ted C. Feigenbaunf Notary Public ExecutiveVice Presidentand Chief Nuclear Officer 9812240143 981216 PDR ADOCK 05000443 P PDR
3 4
l l
1 Section I l
Introduction and Safety Assessment for the Pr oosed Changes l
l I
! Page1
- . . . . - - .. . . .-- . .- - . ~ -. . - -~ _
l s 1<
l %
L INTRODUCTION AND SAFETY ASSESSMENT OF PROPOSED CHANGES
- A. Introduction License Amendment Request (LAR) 98-09 proposes several editorial and administrative changes to the Seabrook Station Technical Specifications (TS). The proposed changes are either to revise references and statements that are inaccurate or provide relief from administrative controls which provide insignificant safety benefit.
B. Proposed Specifications To Be Revised Index Page vi Figures 3.4-2 and 3.4-3 Index Page xv 6.0 Administrative Controls Bases 2.2.1 Reactor Trip System Instrumentation Setpoints 4.2.4.2b Determination of Quadrant Power Tilt Ratio Bases 3/4.2.4 . Quadrant Power Tilt Ratio Bases 3/4.2.5 DNB Parameters Bases 3/4.4.8 Specific Activity Bases 3/4.5.1 Accumulators 6.4.1.7b. SORC Responsibilities 6.4.2.2d. Station Qualified Reviewer Program 6.3.1 Training I 6.4.3.9c. Records of NSARC l 1
.6.8.1.6b.1 Core Operating Limits Report 6.8.1.6.b.10 Core Operating Limits Report C. Safety Assessment of Proposed Changes The first proposed editorial change is to Technical Specifications Index Page vi to indicate that the
! service period, as shown on TS Figures 3.4-2 and 3.4-3 for the Reactor Coolant System (RCS)
Heatup/Cooldown Limitation curves, is applicable up to 11.1 effective full power years (EFPY). The
- change was inadvertently omitted during submittal of LAR 92-06, " Revised RCS Pressure / Temperature Limits," dated August 17,1992, when the service period for RCS heatup and cooldown rate curves was revised from 16 EFPY to 11.1 EFPY, as subsequently approved by License Amendment 19, issued April j 7,1993.
! ~ The second editorial change 'is to TS Index Page xv. The change will add reference to TS 6.15,
. Containment Leakage Rate Testing Program. TS 6.15 was previously approved in License Amendment l 49, issued February 24,1997. The reference was inadvertently omitted during submittal of LAR 96-05,
" Implementation of 10 CFR 50 Appendix J, Option B, Containment Leakage Rate Testing (TAC
, .M95312)," dated June 4,1996. The proposed change is an editorial change for reference purposes only.
l Page 2 l
e ?
, i inclusion of TS 6.15 in the Technical Specifications Index is for completeness and will allow the user an easy method oflocating TS 6.15 within the Technical Specifications Manual.
The third editorial chnge is to Bases 2.2.1, " Reactor Trip System Instrumentation Setpoints, ;
Undervoltage and Underfrequency - Reactor Coolant Pump Busses." to change the underfrequency time delay reference of 0.3 second to 0.6 second. The current value provided in the Bases is background information which is inconsistent with other North Atlantic design documents. The proposed change is consistent with the value contained in the Seabrook Station Technical Requirements Manual and other North Atlantic design documents, as well as the value used in the Seabrook Station Cycle 5 Reactor Coolant Pump Underfrequency Loss of Flow Accident (LOFA) analysis. The use of a time delay of 0.6 ;
seconds in the analysis is conservative relative to 0.3 seconds. i The fourth editorial change is to Quadrant Power Tilt Ratio Surveillance Requirement 4.2.4.2b to change I the current reference of TS 3.3.3.2 to Technical Requireuent TR20-3.3.3.2. LAR 96-02," Relocation of Selected Technical Specifications to Licensee Controlled Documents - Incore Detector System, Seismic j instrumentation, Meteorological Instrumentation and Turbine Overspeed Protection (TAC M96723)", l dated October 17,1996, and subsequently approved as License Amendment 50, issued March 12,1997, )
inadvertently omitted the change in reference to reflect the relocated Incore Detector System technical j specification from Technical Specifications to the Seabrook Station Technical Requirements (SSTR) i Manual. Presently, there is an interim administrative control measure to refer to the SSTR.
The fifth editorial change is to TS 6.4.3.9c to revise reference to TS 6.4.2.8 to TS 6.4.3.8. Seabrook Station Technical Spec,fications does not contain TS 6.4.2.8. TS 6.4.3.8 is the correct reference concerning audits.
.The sixth editorial change is to TS 6.8.1.6.b.l. to refer to the correct date of issue, with issued addenda, of WCAP-ll524-A. The correct issue is WCAP-il524-A, Rev. 2 with Addenda, March 1987. Both
Analysis Report supplied by Westinghouse via letter 93NA*-G-0037, August 31, 1993, which was :
submitted in support of License Amendment 33, issued November 23, 1994, to the Technical l Specifications. There has been no change in the methodology actually applied since approval of j Amendment 33. !
The seventh editorial change is to TS 6.8.1.6.b.10. to revise Yankee Atomic Electric Company document number YAEC-1855P to YAEC-1855PA so that the Technical Specification is consistent with the Core Operating Limits Report (COLR) supporting documentation. This revision reconciles differences between the Cycle 5 COLR references stated in TS 6.8.1.6.b.10. and the references contained in the Seabrook Station Cycle 5 Core Reload Safety Evaluation, YAEC-1925, dated 10/2/95. The reference in YAEC-1925, "YAEC-1855PA," refers to a re-issuance of the submitted YAEC-1855P topical report to the NRC Staff signifying that it was approved by the NRC Staff. The difference between the two reports is that YAEC-1855PA was modified to include a copy of the NRC Staff's SER and TER for YAEC-1855P, as well as copies of the review questions and responses with no changes to the technical content of the report. Preparation of an approved version of the topical report is in keeping with NRC Staff recommendations. These reports describe the Fixed Incore Detector System Analysis methodology which was submitted in support of Amendment No. 27, issued December 22,1993, to the Technical Specifications. There has been no change in the methodology actually applied since approval of Amendment 27. The current Cycle 6 Reload Safety Evaluation refers to the same YAEC document reference, i.e., YAEC-1855PA.
The eighth editorial change is to TS Bases 3/4.2.4, " Quadrant Power Tilt Ratio," to correct an inaccurate statement that states the Quadrant Power Tilt Ratio (QPTR) is set equal to zero during normal power operation. In actuality, QPTR is set to 1.0 during normal power operation. Setting QPTR to 1.0 equates Page 3
1 4
to a Hux tilt of 0%. The correction would make Bases 3/4.2.4 consistent with TS 3.2.4 Action a., which requires a power reduction if indicated QPTR is in excess of 1.
The ninth editorial change is to retract TS Bases 3/4.2.5, Amendment 34, and reinstate the wording in TS Bases 3/4.2.5, License Amendment 33, issued November 23,1994. License Amendment 34, issued January 26, 1995, to TS Bases 3/4.2.5 does not reDect the proposed changes that North Atlantic previously submitted in LARs 93-18 and 93-20, dated 11/23/93 and 1/14/94, respectively. LAR 93-20
" Wide Band Operations and Core Enhancements (TAC .M87849)," and LAR 93-20, " Administrative and Editorial Changes (TAC M86712)," both proposed changes to TS Bases 3/4.2.5. However, during a recent review of the Seabrook Station Technical Specifications, it appears that TS Bases 3/4.2.5, Amendment 34, was issued by the NRC Staff without the revisions made previously in License Amendment 33. License Amendment 34 to TS Bases 3/4.2.5 (with exception of adding the word
" pressure") esser'ially reverted to the previous Amendment 12 version, issued August 10,1992, that Amendment 33 subsequently revised. Review of TS Bases 3/4.2.5, Amendment 33, redects the incorporation of the changes proposed by both LARs 93-18 and 93-20. Review of the remainder of the Seabrook Station Technical Specifications did not reveal similar oversights.
The first administrative change is to clarify TS Bases 3/4.5.1, " Accumulators," to state that during Modes 1 and 2 operation the accumulator power-operated isolation valves are considered to be
" operating bypasses" in the context ofIEEE Std. 279-1971, which require that bypasses of a protective function be removed automatically whenever permissive conditions are not met. During Modes 1 and 2 operation, the accumulator isolation valves receive a signal to open (if closed) whenever pressurizer pressure is above the automatic unblock setpoint (approx.1950 psig) derived from P-ll. During Modes 3 and 4 whenever the accumulators are required to be Operable and pressurizer pressure is below the automatic unblock setpoint but above 1000 psig, the isolation valves are administratively open with their power removed. During this condition of operation the accumulator isolation valves are not in compliance with IEEE Std. 279 to be considered as " operating bypasses" since the automatic unblock signal is unavailable. The proposed change is consistent with the Westinghouse Owners Group Improved Technical Specification Conversion Review, as noted in Westinghouse Nuclear Safety Advisory Letter, N ASL-97-003, " Operating Bypass," dated July 23,1997.
The second administrative change is to TS Bases 3/4.4.8, " Specific Activity," to delete the paragraph which describes the time interval for obtaining and counting reactor coolant samples. The paragraph, as currently written, is not reDective of current technology and methods. The description and times for analyses are based on " gross counts," which was a method used for analysis that did not yield specific isotopic activity. The Bases was written for a sodium iodide detector which determines total gamma counts. This type of detector was replaced with more accurate intrinsic germanium detectors that are more sensitive and capable of providing a profile of specific isotopic activity without further analysis to differentiate potential reactor coolant system problems, e.g., crud, fuel defects. In addition, TS 3/4.4.8 i does not specifically require " gross counting" but rather, the determination of gross radioactivity which l is the sum of all the individual radionuclides' activity determined by the current gamma analytical )
method. As such, 'nclusion of this paragraph in the Bases does not provide additional critical i information to support TS 3/4.4.8; therefbre, deletion of this paragraph will have no effect on plant j safety.
The third administrative change is to delete TS 6.3.1, " Training." TS 6.3.1 requires maintenance of a retraining and replacement licensed training program for the station Staff. The basis for this deletion is that the training / retraining program information contained in TS 6.3.1 is currently, comparably addressed I in UFSAR Chapter 13. In addition, training and re-qualification of those positions are as specified in 10 CFR 55 and 10 CFR 50.120, and as delineated in the institute of Nuclear Power Operations (INPO) I Accredited Program Descriptions for licensed training programs. The INPO Program Descriptions are Page 4 l
1
P e
l l
consistent with the 1989 licensing commitment (Letter NYN-89144 from Ted C. Feigenbaum to NRC, l "FSAR Section 13.2," dated November 13,1989) to comply with Regulatory Guide 1.8, Revision 2, as l discussed with the NRC Staff. Likewise, the UFSAR contains the standards to which station Staff personnel are qualified to. Changes to the UFSAR are pursuant to the provisions of 10 CFR 50.59, therefore, the level of administrative control for the license training program remains comparable. Plant safety will not be adversely affected as a result of deleting TS 6.3.1. A similar change was approved for R. E. Ginna Nuclear Power Plant as License Amendment 61 to Facility Operating License No. DPR-18, l dated February 13,1996.
' The fourth administrative change is to TS 6.4.1.7b to exclude reference to TS 6.4.1.6c. and e.. Presently, TS 6.4.1.7b. requires the Station Operation Review Committee (SORC) to render determinations in writing with regard to whether or not each item considered under Specification 6.4.1.6a. through e.
l constitutes an unreviewed safety question (USQ). TS 6.4.1.6c. specifies that the SORC shall be l responsible for review of all proposed changes to Appendix "A" Technical Specifications. TS 6.4.1.6e.
l requires SORC investigation of all violations of the Technical Specifications, including the preparation l and forwarding of reports covering evaluation and reccmmendations to prevent recurrence, to the Executive Vice President & Chief Nuclear Officer and to the Nuclear Safety Audit Review Committee (NSARC).
With regard to TS 6.4.1.6c., proposed changes to Appendix "A" Technical Specifications are made in accordance with 10 CFR 50.90, 50.91 and 50.92, which require NRC Staff approval prior to implementation. The NRC Staff amends Ucenses based on its determination that no significant hazards l are associated with the proposed change and based on its safety evaluation of the proposed change. The l requirement under TS 6.4.1.7b. for the SORC to render determinations as to whether proposed changes
! to Appendix "A" Technical Specifications constitutes a USQ is an administrative control that provides
! insignificant safety benefit because, regardless if a USQ exists or not, all changes to Technical Specifications must receive NRC Staff approval prior to implementation, therefore, this additional administrative control is unnecessary. Plant safety will not be adversely affected as a result of not requiring the SORC to render determinations in writing as to whether or not proposed changes to Appendix "A" Technical Specifications constitutes a USQ.
With regard to TS 6.4.1.6e., the requirement for the SORC to determine in writing as to whether all violations of the Technical Specifications constitutes a USQ is unnecessary, as well. The determination if a USQ existed at the time of the TS violation is, essentially, a retrospective review of a temporary
! condition which provides little benefit, if any, to the continued safe operation of the facility. Safe l operation of the facility is governed by the Limiting Conditions For Operation (LCOs) and associated j Actions and Surveillance Requirements stated in TS, as required by the provisions of 10 CFR 50.36.
When a LCO is not met,10 CFR 50.36 requires the licensee to shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. Return of plant operation or condition in compiiance with the requirements of the TS assures continued safe operation of the facility and nullifies the potential USQ condition that the plant may have been operating under at the l time of the TS violation. In addition, any operation or condition prohibited by the Technical Specifications require reporting pursuant to the provisions of 10 CFR 50.72 and 10 CFR 50.73.
S~ old a licensee desire to operate the facility outside the requirements currently specified in TS, then, th . licensee must either seek an amendment to the current Operating License pursuant to the provisions of 10 CFR 50.90,50.91, and 50.92, or seek issuance of a Notice of Enforcement Discretion (NOED) pursuant to NUREG-1600, " General Statement of Policy and Procedures for NRC Enforcement Actions," (with a supporting safety basis for the temporary condition and, if permanent, a follow up license amendment request), both of which require NRC Staff approval prior to continued operation.
The NRC Staff amends licenses based on its determination that no significant hazards are associated with l
Page 5 i
, P 4
the proposed change and based on its safety evaluation of the proposed change 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) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. In essence, a USQ does not exist, it is concluded that the requirement to review TS violations that occurred temporarily to determine if a USQ existed at the time of the TS violation is an unnecessary burden that directs the SORC from its primary responsibilities and provides little, if any, benefit to assure continued safe operation of the facility. SORC will continue to investigate TS violations and make appropriate recommendations to prevent recurrence. Therefore, the proposed change will not adversely affect the present administrative controls to assure continued safe operation of the facility. Other facilities, e.g., Callaway and Millstone Unit 3, do not require their comparable SORC to render a determination if a USQ existed at the time of the TS violation.
The fifth administrative change is to TS 6.4.2.2d. to reflect that Station Qualified Reviewers, need only be trained and qualified to perform 10 CFR 50.59 screenings in lieu of 10 CFR 50.59 evaluations. The proposed change would make TS 6.4.2.2d. consistent with TS 6.4.2.2e. which states " . that the procedure or program was screened by a qualified individual and found not to require a 10 CFR 50.59 evaluation." The Station Qualified Reviewer Program, as outlined in TS 6.4.2, has provision for qualified individuals who perform reviews of designated procedures, programs, and changes thereto considered under TS 6.4.1.6a. to perform 10 CFR 50.59 screenings to determine if further evaluation, under the provisions of 10 CFR 50.59, is warranted in the determination that an unreviewed safety question does or does not exist. To perform 10 CFR 50.59 screenings, it is not necessary that these individuals be specifically trained and qualified in performing 10 CFR 50.59 safety evaluations. Itis recognized that these individuals, who perform screenings, be familiar with the entire 10 CFR 50.59 process, however, other individuals specifically trained and qualified to perform 10 CFR 50.59 evaluations may be designated to perform this task. The requirements of ensuring that a 10 CFR 50.59 evaluation is performed is specified in TS 6.4.2.2e. TS 6.4.2.2e. requires that a written recommendation by the Qualified Reviewer (s) to the responsible department head for the approval or disapproval of procedures and programs that are considered under TS 6.4.1.6a. Furthermore, the requirements of TS 6.4.2.3 requires that if the department head determines that a 10 CFR 50.59 evaluation is necessary the department head will ensure that a 10 CFR 50.59 evaluation is performed and presented, along with the new procedure, program or proposed change, to the SORC for review. Plant safety will not be adversely affected as a result of this change since the level of administrative control in the review of designated procedures, programs and changes thereto considered under TS 6.4.1.6a essentially remains the same.
l Page 6
.- .. - . ~ - - - . . . . - . - - .
7 l l
I I
l l
l Section II 2
Markup of Proposed Changes 1
The attached markup reflects the currently issued revision of the Technical Specifications listed i below. Pending Technical Specifications or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed markup.
l The following Technical Specification pages are included in the attached markup:
Technical Specification Title Page I Index Figures 3.4-2 and 3.4-3 vi l Index 6.0 Administrative Cont ols xv ;
i
! Bases 2.2.1 Reactor Trip System Instrumentation Setpoints B 2-7 4.2.4.2b Determination of Quadrant Power Tilt Ratio 3/42-9 l l Bases 3/4.2.4 Quadrant Power Tilt Ratio B 3/4 2-3
- l l Bases 3/4.2.5 DNB Parameterr B 3/4 2-4 Bases 3/4.4.8 Specific Activity B 3/4 4-6 l l : Bases 3/4.5.1 Accumulators B 3/4 5-1 6.3.1 Training 6-5 6.4.1.7b'. SORC Responsibilities 6-8 6.4.2.2d. Station Qualified Reviewer Program 6-8A l 6.4.3.9c. Records of NSARC 6-11 6.8.1.6.b.1 Core Operating Limits Report 6-18A
! 6.8.1.6.b.10 Core Operating Limits Report 6-18C l l l
Page 7