ML13037A089

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Seabrook Station, Supplement to License Amendment Request 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System
ML13037A089
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 01/31/2013
From: Walsh K T
NextEra Energy Seabrook
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-12266, TAC ME3988
Download: ML13037A089 (14)
v • d • e


Text

NEXTeraENERG-YV,January 31, 201310 CFR 50.90SBK-L-1 2266Docket No. 50-443U. S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001Seabrook StationSupplement to License Amendment Request 10-02, "Application for Change to the TechnicalSpecifications for the Containment Enclosure Emergency Air Cleanup System"References:1. NextEra Energy Seabrook, LLC letter SBK-L-1 0074, "Application for Change to theTechnical Specifications for the Containment Enclosure Emergency Air CleanupSystem," May 14, 20102. NextEra Energy Seabrook, LLC letter SBK-L-10143, Response to Request for AdditionalInformation Regarding License Amendment Request (LAR) 10-02, "Application forChange to the Technical Specifications for the Containment Enclosure Emergency AirCleanup System," August 24, 20103. NextEra Energy Seabrook, LLC letter SBK-L-1 1184, Response to Request for AdditionalInformation Regarding License Amendment Request 10-02, Regarding the ContainmentEnclosure Emergency Air Cleanup System, September 16, 20114. NextEra Energy Seabrook, LLC letter SBK-L-12054, Response to Request for AdditionalInformation Regarding License Amendment Request 10-02, "Application for Change tothe Technical Specifications for the Containment Enclosure Emergency Air CleanupSystem," March 15, 20125. NRC letter "Seabrook Station, Unit 1 -Request for Additional Information Regarding theAddition of Action Statement to Limiting Condition for Operation 3.6.5.1, "ContainmentEnclosure Emergency Air Cleanup System" (TAC No. ME3988)," June 11, 20126. NextEra Energy Seabrook, LLC letter SBK-L-1 2124, Response to Request for AdditionalInformation Regarding License Amendment Request 10-02, Regarding the ContainmentEnclosure Emergency Air Cleanup System, July 2, 2012NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874 A 00 United States Nuclear Regulatory CommissionSBK-L-1 2266 / Page 2In Reference 1 and supplemented by References 2, 3, 4, and 6, NextEra Energy Seabrook, LLC(NextEra) submitted a request for an amendment to the Technical Specifications (TS) forSeabrook Station. The proposed amendment would relocate TS Surveillance Requirement (SR)4.6.5.1 .d.4, which verifies the ability to establish a negative pressure in the containmentenclosure building, so that it will demonstrate integrity of the containment enclosure buildingrather than operability of the containment enclosure emergency air cleanup system. Theamendment relocates SR 4.6.5.1.d.4 with modifications as new SR 4.6.5.2.b. Additionally, theamendment makes some minor wording changes, deletes a definition, and removes an expiredfootnote.The proposed change would resolve a discrepancy in required actions between TS 3.6.5.1 forthe Containment Enclosure Emergency Air Cleanup System (CEEACS), and TS 3.6.5.2,Containment Enclosure Building Integrity. Currently, TS 3.6.5.2 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restorecontainment enclosure building integrity. However, the same condition (lack of containmentenclosure building integrity) would require entry into TS 3.0.3 for two inoperable trains ofCEEACS due to an inoperable ventilation area boundary. The proposed change will resolve thisdiscrepancy so that only the actions of TS 3.6.5.2 would apply to a failure to maintaincontainment enclosure building integrity.The NRC issued a similar change in February 1996 for Millstone 3 in Amendment 126. Thesafety evaluation (SE) for the amendment discusses that a conflict was identified relative toMillstone TS 3.6.6.1, Supplementary Leak Collection and Release Systems (SLCRS), duringplanned breaches of the secondary containment. TS 3.6.6.2, Secondary Containment, provides24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore secondary containment boundary operability. However, a planned breach inthe secondary containment would render both trains of SLCRS inoperable (due to the inability tosatisfy the surveillance requirement that demonstrates the ability to establish a negativepressure in the secondary containment). This condition would require a plant shutdown inaccordance with TS 3.0.3. The NRC staff's SE states that the proposed changes will resolvethis problem by decoupling TS 3.6.6.1 and 3.6.6.2; the licensee will, when breaching thesecondary containment, enter only the Action Statements for TS 3.6.6.2. In the event thatsecondary containment operability is not maintained, the Action Statement for LCO 3.6.6.2requires that secondary containment operability must be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Further, theSE states "The staff has determined that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable completion time consideringthe limited leakage design of containment and the low probability of a design basis accidentoccurring during this period." Moreover, the SE states "This situation was recognized by thestaff and has been addressed in the improved standard technical specification for Westinghouseplants (NUREG-1431)."In NUREG-1431, the surveillance requirement that verifies the ability to maintain a negativepressure in the shield building is associated with TS 3.6.8, Shield Building, rather than TS3.6.13, Shield Building Air Cleanup System (SBACS), as a demonstration of shield buildingintegrity. Therefore, a failure to maintain shield building integrity does not render both trains ofthe SBACS inoperable. Furthermore, similar to the change approved for Millstone inAmendment 126, NUREG -1431 provides a 24-hour completion time to restore an inoperableshield building. The basis for this completion time included in NUREG-1431 is also the same asthat approved for Millstone 3: Twenty-four hours is a reasonable Completion Time consideringthe limited leakage design of containment and the low probability of a Design Basis Accidentoccurring during this time period.

United States Nuclear Regulatory CommissionSBK-L-1 2266 / Page 3NextEra is proposing a change to eliminate the TS discrepancy that would require a TS 3.0.3plant shutdown for a failure to maintain containment enclosure building integrity. The currentSeabrook TS provide a 24-hour completion time to restore containment enclosure buildingintegrity; however, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not an acceptable completion time for a loss of function for theSeabrook containment enclosure building because the building access openings contain asingle door. Therefore, to avoid an unnecessary, immediate plant shutdown in the event thatcontainment enclosure building integrity is not maintained, NextEra proposes to supplement therequested amendment. The supplement provides new required actions that are based on thecause of the loss of integrity and includes a new action with a completion time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.NextEra discussed the revised proposed changes with the NRC staff in a conference call onJanuary 17, 2013.Proposed action a provides 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore containment enclosure building integrity whenperforming corrective or preventative maintenance on the containment enclosure boundary orfollowing discovery of an inoperable containment enclosure boundary component (penetrationseal, damper, or access door). Twelve hours is a reasonable completion time considering thelimited leakage design of containment, the low probability of a design basis accident occurringduring this time, and the time required to repair a containment enclosure building door. Further,without containment enclosure building integrity, the containment building spray (CBS) systemprovides additional defense-in-depth for accidents that credit the containment enclosurebuilding. The CBS system functions to remove iodine and reduce containment pressure, whichreduces containment leakage to the containment enclosure. As a result, the CBS systemreduces dose consequences from a release from the primary containment. Without at least oneCBS train operable, the TS require an immediate plant shutdown.Proposed action b provides a 24-hour completion time for the condition in which an operablecontainment enclosure boundary door is held open to support movement of equipment throughthe access opening, or routing hoses, cables, etc., through the access opening. This actionrequires the availability of a dedicated individual with a preplanned method to rapidly close thecontainment enclosure boundary door in the event of actuation of the CEEACS. The dedicatedindividual must be stationed at the door and have continuous communications capability with thecontrol room. Hoses and cables running through the access opening must employ a means thatallows prompt removal of the obstruction to permit closure of the door without delay. Twenty-four hours is a reasonable completion time considering the limited leakage design ofcontainment, the low probability of a DBA occurring during this time, and the availability of adedicated individual to close the containment enclosure boundary door.Attachment 1 provides a revised markup of the TS showing the proposed changes, whichreplaces and supersedes the markup of TS 3.6.5.2 provided in Reference 6, and Attachment 2contains the retyped TS page. Attachment 3 provides revised TS Bases that replace andsupersede the proposed Bases for TS 3.6.5.2 provided in Reference 6. The Bases are providedfor information and will be implemented in accordance with TS 6.7.6.j, TS Bases ControlProgram, upon implementation of the license amendment.The modification to the proposed change does not alter the conclusion in Reference 1 that theproposed change does not involve a significant hazard consideration pursuant to 10 CFR 50.92.

United States Nuclear Regulatory CommissionSBK-L-1 2266 / Page 4A copy of this letter has been forwarded to the New Hampshire State Liaison Officer pursuant to10 CFR 50.91(b).Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe,Licensing Manager, at (603) 773-7745.Sincerely,NextEra Energy Seabrook, LLCKevin T. WalshSite Vice PresidentEnclosurecc: NRC Region I AdministratorJ. G. Lamb, NRC Project Manager, Project Directorate 1-2NRC Senior Resident InspectorPerry E. Plummer, Acting Director, Homeland Security and Emergency ManagementNew Hampshire Department of SafetyDivision of Homeland Security and Emergency ManagementBureau of Emergency Management33 Hazen DriveConcord, NH 03305John Giarrusso, Jr., Nuclear Preparedness ManagerThe Commonwealth of MassachusettsEmergency Management Agency400 Worcester RoadFramingham, MA 01702-5399 NExTeraoENERGY dAFFIDAVITSEABROOK STATION UNIT 1Facility Operating License NPF-86Docket No.50-443Supplement to License Amendment Request 10-02, "Application for Change to theTechnical Specifications for the Containment Enclosure Emergency Air Cleanup System"I, Kevin T. Walsh, Site Vice President of NextEra Energy Seabrook, LLC hereby affirm thatthe information and statements contained within this supplement regarding LicenseAmendment Request 10-02 are based on facts and circumstances which are true andaccurate to the best of my knowledge and belief.Sworn and Subscribedbefore me this\ day of u &. ,2013N~ayPublic)Kevin T. WalshSite Vice President

Attachment

1Markup of TS 3.6.5.2 CONTAINMENT SYSTEMSCONTAINMENT ENCLOSURE BUILDINGCONTAINMENT ENCLOSURE BUILDING INTEGRITYLIMITING CONDITION FOR OPERATION3,6.5.2 BULLDNG I, TE-$RI shall be maintained.APPLICABILITY: MODES 1, 2, 3, and 4.ACTION: '- 'a",,( itho ONTA ~T ENCL S RE BQILDI~G r tore CO~ANM NT)LOS RE DING VJ lFT{Ywith~iq hour or b least ~ S DYwithin =then nt 6hou s and ih.COLD SH LfDOWN with the'follio-w 3 osSURVEILLANCE REQUIREMENTS4.6.5.2 ENT E WO,2'UR EeUI L G Na .shall be demonstratedol-ieasn5 per "lay~sby veifying What the doortn each aclcefssop~eniing is c~losed the accesenin cis beýing used for normal transit entry a~nd exi .Il,?-/4 aye,?1"71SEABROOK -UNIT 13/4 6-24 INSERT NOTE---------------------------------IL jI'--------------------------------------------------Entry into ACTION is not required when the access opening is being usedfor normal transit entry or exit.............................................................................................................INSERT ACTIONSa. Without containment enclosure building integrity for reasons other than Action b, restorecontainment enclosure building integrity within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Otherwise be in at least HOTSTANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30hours.b. Without containment enclosure building integrity when equipment ingress and egressrequires the access door to be maintained open, verify a dedicated individual, who is incontinuous communication with the control room, is available to rapidly close the door;and restore containment enclosure building integrity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise be in atleast 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 /> and in COLD SHUTDOWN within thefollowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Attachment

2Retyped Page for TS 3.6.5.2 CONTAINMENT SYSTEMSCONTAINMENT ENCLOSURE BUILDINGCONTAINMENT ENCLOSURE BUILDING INTEGRITYLIMITING CONDITION FOR OPERATION3.6.5.2 Containment enclosure building integrity shall be maintained.APPLICABILITY: MODES 1, 2, 3, and 4.------------------------NOTE ---------------------------Entry into ACTION is not required when the access opening is being usedfor normal transit entry or exit.ACTION:a. Without containment enclosure building integrity for reasons other than Action b, restorecontainment enclosure building integrity within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Otherwise be in at least HOTSTANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30hours.b. Without containment enclosure building integrity when equipment ingress and egressrequires the access door to be maintained open, verify a dedicated individual, who is incontinuous communication with the control room, is available to rapidly close the door;and restore containment enclosure building integrity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise be in atleast 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 /> and in COLD SHUTDOWN within thefollowing 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />sSURVEILLANCE REQUIREMENTS4.6.5.2 Containment enclosure building integrity shall be demonstrated:a. At least once per 31 days by verifying that the door in each access opening isclosed except when the access opening is being used for normal transit entryand exit, andb. At least once per 36 months on a STAGGERED TEST BASIS by verifying thecontainment enclosure building can be maintained at a negative pressuregreater than or equal to 0.25 inch water gauge by one train of the containmentenclosure emergency air cleanup system within 4 minutes after a start signal.SEABROOK -UNIT 13/4 6-23Amendment No.

Attachment

3Bases for TS 3.6.5.2 3/4.6.5.2 CONTAINMENT ENCLOSURE BUILDING INTEGRITYBACKGROUNDThe containment enclosure building is a reinforced concrete right cylindrical structure with ahemispherical dome that is located outside and surrounds the containment building. Thisstructure provides leak protection for the containment and protects it from certain loads (normalloads, loads due to severe and extreme environmental conditions, and abnormal loads). Thespace between the containment and the enclosure building is maintained at a slight negativepressure during accident conditions. All joints and penetrations are sealed to ensure airtightness.Without containment enclosure building integrity, the containment building spray (CBS) systemprovides additional defense-in-depth for accidents that credit the containment enclosurebuilding. The CBS system functions to remove iodine and reduce containment pressure, whichreduces containment leakage to the containment enclosure. As a result, the CBS systemreduces dose consequences from a release from the primary containment. When Action a or bis entered, the plant can continue to operate at power if at least one CBS train is operable inaccordance with TS 3.6.2.1.APPLICABLE SAFETY ANALYSESThe function of the containment enclosure building is to collect any fission products which couldleak from the primary containment structure into the containment enclosure and contiguousareas following a LOCA. The containment enclosure provides a barrier between thecontainment and the environment to control all leakage out from the containment boundary.Containment enclosure building integrity ensures that the release of radioactive materials fromthe primary containment atmosphere will be restricted to those leakage paths and associatedleak rates assumed in the safety analyses. This restriction, in conjunction with operation of thecontainment enclosure emergency air cleanup system (CEEACS), will limit radiation dose towithin the dose guideline values of 10 CFR 50.67 during accident conditions.The containment enclosure building satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).LCOContainment enclosure building integrity must be maintained to limit the release of radioactivematerials from the primary containment atmosphere to those leakage paths and associated leakrates assumed in the safety analyses. Containment enclosure building integrity exists when (1)each door in each access opening is closed except when the access opening is being used fornormal transit entry and exit, (2) the sealing mechanism associated with each containmentenclosure building penetration (e.g., welds, bellows, or 0-rings) is OPERABLE, and (3) thecontainment enclosure building functions as designed to maintain the required negativepressure.APPLICABILITYMaintaining containment enclosure building integrity prevents leakage of radioactive materialfrom the enclosure building. Radioactive material may enter the containment enclosure buildingfrom the containment following a DBA. Therefore, containment enclosure integrity is required in1 MODES 1, 2, 3, and 4 when a DBA could release radioactive material to the containmentatmosphere. In MODES 5 and 6, the probability and consequences of these events are low dueto the Reactor Coolant System temperature and pressure limitations in these MODES.Therefore, containment enclosure building integrity is not required in MODE 5 or 6.ACTIONSA Note states that entry into the Actions is not required when an access opening (containmentenclosure boundary door) is being used for normal transit entry and exit. This provision providesan exception to TS 3.0.1 when containment enclosure integrity is not maintained while anaccess door is open for normal transit. This note is consistent with SR 4.6.5.2.a, which requireseach containment enclosure boundary door to be closed except during normal transit entry andexit.Action a.Action a addresses a loss of containment enclosure building integrity for reasons other thanprovided in Action b. For example, this action is applicable when performing preventative orcorrective maintenance on the containment enclosure building boundary, including containmentenclosure building penetration seals, dampers and access doors, that results in a failure tomaintain containment enclosure building integrity. The containment enclosure building accessopenings contain a single door, so opening a door causes a loss of containment enclosureintegrity.Containment building enclosure integrity must be restored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Twelve hours is areasonable completion time considering the limited leakage design of containment, the lowprobability of a DBA occurring during this time, and the time required to repair a containmentenclosure building door.Action b.Action b addresses the condition in which an OPERABLE containment enclosure boundary dooris held open to support movement of equipment through the access opening, or routing hoses,cables, etc., through the access opening. Thus, this action applies when containment enclosurebuilding integrity is not maintained due to an open access door for equipment ingress andegress because the doorway must be maintained open, i.e., obstructed, for equipment, cables,hoses, etc., such that it cannot be immediately closed. Additionally, pressure boundary sealsmust also be intact to maintain the integrity of the containment enclosure. Action b does notapply to normal transit entry and exit.Action b requires the availability of a dedicated individual with a preplanned method to rapidlyclose the containment enclosure boundary door in the event of actuation of the CEEACS. Thededicated individual must be stationed at the door and have continuous communicationscapability with the control room. Hoses and cables running through the access opening mustemploy a means that allows prompt removal of the obstruction to permit closure of the doorwithout delay.Containment building enclosure integrity must be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Twenty-four hours isa reasonable completion time considering the limited leakage design of containment, the lowprobability of a DBA occurring during this time, and the availability of a dedicated individual toclose the containment enclosure boundary door.2 SURVEILLANCE REQUIREMENTSSR 4.6.5.2.aThe containment enclosure boundary doors are normally maintained closed except when theaccess opening is being used for entry and exit. Verifying containment enclosure buildingintegrity involves confirming that the doors are closed except during normal transit entry and exit.Normal transit includes opening doors as necessary to permit the movement of people andequipment through the doorway. This may also include opening doors to test actuation of dooralarms. Propping open a door and obstructing the doorway with equipment, cables, hoses, etc.,such that it cannot be immediately closed is not normal transit entry and exit. Additionally,pressure boundary seals must also be intact to maintain the integrity of the containmentenclosure.SR 4.6.5.2.bThe CEEACS is used to establish a negative pressure in the containment enclosure building.SR 4.6.5.2 verifies containment enclosure building integrity by drawing down the containmentenclosure building to a negative pressure greater than or equal to 0.25 inch Water Gauge usingone train of CEEACS within four minutes after a start signal to ensure that the building can meetits design negative pressure in less than eight minutes following the initiation of a LOCA.Inoperability of the containment enclosure building does not by itself render the CEEACSinoperable. Therefore, the Action of TS 3.6.5.1 (CEEACS) is not required to be entered solelydue to a failure to maintain containment enclosure building integrity.Since this SR is a containment enclosure building boundary integrity test, it does not need to beperformed at each surveillance interval with each CEEACS train. The CEEACS train used forthis SR is scheduled on a STAGGERED test basis to ensure that either train will perform thetest. The primary purpose of this SR is to ensure containment enclosure building integrity. Thesecondary purpose of this SR is to ensure that the CEEACS train used for the test functions asdesigned. Inoperability of the CEEACS train does not necessarily constitute a failure of this SRrelative to containment enclosure building integrity.3

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