ML20217N821

Proposed Tech Specs 4.5.2B.1,excluding Prescriptive Requirement to Vent Operating CVCS CCP Casing

ML20217N821
Person / Time
Site:	Seabrook
Issue date:	03/02/1998
From:	NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
Shared Package
ML20217N811	List: ML20217N807 ML20217N815 ML20217N821
References
NUDOCS 9803090231
Download: ML20217N821 (9)

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Section II Markup of the Proposed Change Please note that the attached markups reflect 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 included in the attached markup:

Technical Specification Title Page(s)

TS 4.5.2h.1 ECCS Subsystems - 3/4 5-5 T , Greater Than OR Equal To 350 F i

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age 4 9903090231 980302 PDR ADOCK 05000443  ;

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. '. EMERGENCY CORE COOLING SYSTEMS

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f ECCS SUBSYSTEMS - Ty GREATER THAN OR EDUAL'TO 350*F SURVEILLANCE REQUIREMENTS - 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying that the following valves are in the indicated positions with power to the valve operators removed: ,

J ValvENumber Valve Function Valve Position $

SI-V-3 Accumulator Isolation Open*

SI-V-17 Accumulator Isolation Open*

SI-V-32 Accumulator Isolation Open*

, SI-V-47 Accumulator Isolation Open*

SI-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 SI-V-77 SI to Hot-Leg Isolation Closed

" ..:) SI-V-102 SI to Hot-Leg Isolation Closed

b. At least once per 31 days by:

1) Verifying that the ECCS pipink is full of water by venting

! the ECCS pump casings and accessible discharge piping high Tid pfMv Points, and Verifying that each valve (manual, power-o rated, or 1

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automatic) in the flow path that is not lo ed, sealed, or OA 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 contiinment which could be transported t.o 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 CONTAINNENT INTEGRITY, and

2) At least once daily of the areas affected within containment j by containm3nt entry and durfng the final entry when primary CONTAllMENT INTEGRITY is established. (

• Pressurizer pressure above 1000 psig.

O SEABROOK - UNIT 1 3/4 5-5 Amendment No.

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SECTION III Retype of the Proposed Change Please note that the attached retype of the proposed change to the Technical Specifications reflects the currently issued version of the Technical Specifications. Pending Technical Specification j changes or Technical Specification changes issued subsequent to this submittal are not reflected in I the enclosed retype. The enclosed retype should be checked for continuity with Technical Specifications prior to issuance.

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EMERGENCY CORE CCOLING SYSTEMS ECCS SUBSYSTEMS - T,, GREATER THAN OR EOUAL TO 350 F SURVEILLANCE REOUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

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a. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying that the following valves are in the indicated positions with power to the valve operators removed:

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

l SI-V-17 Accumulator Is01ation Open*

SI-V-32 Accumulator Isolation Open*

SI-V-47 Accumulator Isolation Open*

SI-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 i RH-V-70 RHR to Hot-Leg Isolation Closed SI-V-77 SI to Hot-Leg Isolation Closed SI-V-102 SI to Hot-Leg Isolation Closed

b. At least once per 31 days by:

1) Verifying that the ECCS piping is full of water by venting the ECCS pump casings (excluding the operating centrifigual charging pump) and accessible discharge piping high points, 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 Jump suctions during LOCA conditions. This visual inspection shall 3e performed:

1) For all accessible areas of the containment prior to establishing primary CONTAINMENT INTEGRITY and

2) At least once daily of the areas afrected within containmcnt by containment entry and during the t inal entry when primary CONTAINMENT INTEGRITY is established.

• Pressurizer pressure above 1000 psig.

SEABROOK - UNIT 1 3/4 5-5 Amendment No. 30 l

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i Section IV Determination of Significant Hazards for the Proposed Change l

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IV... DETERMINATION OF SIGNIFICANT HAZARDS FOR THE PROPOSED CHANGE License Amendment Request (LAR) 98-01 proposes a change to Seabrook Station Techaical Specification (TS) Surveillance Requirement TS 4.5.2b.1 to exclude the prescriptive requirement to vent the operating Chemical Volume and Control System (CVCS) centrifugal charging pump (CCP) casing.

Mandatory venting of the operating CCP is unnecessary since the CCPs are designed and installed to be self-venting, particularly when operating under dynamic conditions.

In accordance with 10 CFR 50.92, North Atlantic has reviewed the attached proposed change and has concluded that it does not involve a significant hazards consideration (SHC). The basis for the conclusion that the proposed change does not involve a SHC is as follows:

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change does not affect accident initiators or precursors and does not alter the design assumptions affecting the ability of the ECCS pumps to mitigate the consequences of an accident.

The proposed change will align the surveillance requirements with the installed system design and normal operating conditions. The intent of the surveillance requirement ensures operabilhy of the CVCS centrifugal charging pumps by verifying that the ECCS pumps and piping is full of water and not subjected to gas binding or hydraulic transients.

Excluding the venting of the operating CVCS centrifugal charging pump will not effect pump operation nor subject the high head safety injection portion of the ECCS to potential hydraulic transients. Venting the operating pump under a dynamic condition at high system pressure is ineffective.

The design and installation of the CVCS centrifugal charging pumps is such that significant non-condensable gasses do not collect in the pumps, whether they are running or not. Therefore, it is unnecessary to require periodic pump casing venting to ensure the pumps will remain operable.

Venting of the non-operating centrifugal charging pump will continue to be performed, as required by TS 4.5.2b.l.

'llerefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of accident from any previously aralyzed.

The proposed change will not result in new failure modes because no new components or physical changes are involved with this change nor are the components operated in a new or different manner. The proposed change does not alter the ability of the CVCS centrifugal charging pumps to perform their intended function to mitigate the consequences af an initiating event within the acceptance limits assumed in the Updated Final Safety Analysis Report Page 7

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. . (UFSAR). The proposed change has no impact on component or system interactions, or the plant design basis. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously analyzed.

3. The proposed change does not involve a significant reduction in a margir of safety.

There is no impact on equipment design or operation and there are no changes being made to the Technical Specification required safety limits or safety system settings that would adversely affect plant safety. The CVCS centrifugal charging pumps are designed and installed to be self-venting, such that, accumulation, if any, of non-condensable gasses would have no significant impact on pump operation Since the proposed change will not result in new failure modes, then, the designed marg.as of safety to minimize /proclude the consequences of a radiological event resulting from a design basis accident remain unchanged. Therefore, the proposed change to diminate the requirement to ve it the operating CVCS centrifugal charging pump casing does not involve a significant reduction in any margin of safety.

Based on the above evaluation, North Atlantic concludes that the proposed change does not constitu% a significant hazard.

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Sections V & VI 1 Proposed Schedule for License Amendment Issuance and Effectiveness <

and l EnvironmentalImpact Assessment i

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V. ,, PROPOSED SCHFDULE FOR LICENSE AMENDMENT ISSUANCE AND EFFECTIVENESS North Atlantic requests NRC review of License Amendment Request 98-01 and issuance of a license amendment by March 31,1998, having immediate effectiveness and implementation required within 60 days.

VI. ENVIRONMENTAL IMPACT ASSESSMENT North Atlantic has reviewed the proposed license amendment against the criteria of 10 CFR 51.22 for environmental considerations. The proposed change does 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 10 CFR S t.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

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