SBK-L-14024, License Amendment Request (LAR) - 14-01, Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler - 523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated.

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License Amendment Request (LAR) - 14-01, Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler - 523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated.
ML14177A503
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 06/24/2014
From: Dean Curtland
NextEra Energy Seabrook
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 14-01, SBK-L-14024
Download: ML14177A503 (31)
v • d • e


Text

NExTera ENERGY n SEABROK June 24, 2014 SBK-L-14024 10 CFR 50.90 Docket No. 50-443 Facility Operating License No. NPF-86 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station License Amendment Request (LAR) 01, Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF) Traveler -523, "Generic Letter 2008-01, Managing Gas Accumulation," Using the Consolidated Line Item Improvement Process References

1. Letter (SBK-L-08179) from G. St. Pierre (FPL Energy Seabrook, LLC) to Document Control Desk (NRC), "Nine Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," October 14, 2008 (ADAMS Accession No. ML082910040)

Pursuant to 10 CFR 50.90, NextEra Energy Seabrook, LLC (NextEra) is submitting a request for amendment to the Technical Specifications (TS) for Seabrook Station (Seabrook), Unit 1.

The proposed amendment would modify TS requirements to address NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in.Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in TSTF-523, Revision 2 "Generic Letter 2008-01, Managing Gas Accumulation." NextEra committed to submit this proposed change in Reference 1. provides a description and assessment of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides existing TS Bases pages marked to show the proposed change. Changes to the existing TS Bases, consistent with the technical and regulatory analyses, will be implemented under the Technical Specification Bases Control Program. They are provided in Attachment 3 for information only. New TS pages with the proposed change incorporated will be provided when requested by the NRC Project Manager.

4A SQ

U. S. Nuclear Regulatory Commission SBK-L-14024/Page 2 of 3 Approval of the proposed amendment is requested by June 30, 2015. Once approved the amendment will be implemented within 60 days.

The Station Operation Review Committee has reviewed this LAR. A copy of this LAR has been forwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91(b).

This letter satisfies NextEra's commitment made in Reference I and makes no new commitments or changes to any other existing commitments.

If you have any questions or require additional information, please contact Michael Ossing at 603-773-7512.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June '__, 2014.

Sincerely, NextEra Energy Seabrook, LLC Dean Curtland Site Vice President

U. S. Nuclear Regulatory Commission SBK-L-14024/Page 3 of 3 Attachments: 1. Description and Assessment

2. Proposed TS Changes (marked-up pages)
3. Proposed TS Bases Changes (marked-ups pages) - For information only cc: USNRC Regional Administrator, Region I J. G. Lamb, USNRC Project Manager, Project Directorate 1-2 USNRC Senior Resident Inspector, Seabrook Station Mr. Perry Plummer, Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA, 01702-5399

SBK-L-14024 Attachment I License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 1 Seabrook Station Description and Assessment

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 3.2 Applicable Regulatory Requirements/Criteria 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

Page 1 of 5

SBK-L-14024 ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification. The changes are being made to address the concerns discussed in NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," [Reference 2].

The proposed amendment is consistent with Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" [Reference 3].

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation NextEra Energy Seabrook, LLC (NextEra) has reviewed the model safety evaluation published January 15, 2014 as part of the Federal Register Notice of Availability "TSTF-523, Generic Letter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item Improvement Process" (79 FR 2700) [Reference 4]. This review included a review of the NRC staff s evaluation, as well as the information provided in TSTF-523. As described in the subsequent paragraphs, NextEra has concluded that the justifications presented in the TSTF-523 proposal and the model safety evaluation prepared by the NRC staff are applicable to Seabrook Station (Seabrook) and justify this amendment for incorporation of the changes to the Seabrook Technical Specifications (TS).

2.2 Optional Changes and Variations NextEra is proposing the following variations from the TS changes described in the TSTF-523, Revision 2 [Reference 3], or the applicable parts of the NRC staff s model safety evaluation.

The Seabrook TS utilize different numbering, format, and titles than NUREG-143 1, "Standard Technical Specifications for Westinghouse Plants" [Reference 5] on which TSTF-523 was based.

Specifically, the differences in numbering and titles are provided in the table below.

Page 2 of 5

SBK-L-14024 NUREG-1431 Seabrook Standard Technical Specifications Technical Specifications Westinghouse Plants 3.4.6, RCS LOOPS - Mode 4 .3/4.4.1.3, Reactor Coolant Loops and Coolant Circulation - Hot Shutdown 3.4.7, RCS LOOPS.- Mode 5 Loops Filled 3/4.4.1.4.1, Reactor Coolant Loops and Coolant Circulation - Cold Shutdown - Loops Filled 3.4.8, RCS LOOPS - Mode 5 Loops Not Filled 3/4.4.1.4.2, Reactor Coolant Loops and Coolant Circulation - Cold Shutdown - Loops Not Filled 3.5.2, ECCS - Operating 3/4.5.2, ECCS Subsystems - Tavg Greater than or Equal to 350TF 3.6.6, Containment Spray and Cooling Systems 3/4.6.2.1, Containment Systems -

Depressurization and Cooling Systems 3.9.5, RHR and Coolant Circulation - High 3/4.9.8.1, Residual Heat Removal and Coolant Water Level Circulation - High Water Level 3.9.6, RHR and Coolant Circulation - Low 3/4.9.8.2, Residual Heat Removal and Coolant Water Level Circulation - Low Water Level These differences are administrative and do not affect the applicability of TSTF-523 to Seabrook.

3.0 REGULATORY SAFETY ANALYSIS 3.1 No Significant Hazards Consideration Determination NextEra requests adoption of Technical Specification Task Force Traveler (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the standard technical specifications (STS), into the Seabrook Station Technical Specifications (TS). The proposed change revises or adds Surveillance Requirements (SRs) to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

NextEra has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1: Does the Proposed Change Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated?

Response: No Page 3 of 5

SBK-L-14024 The proposed change revises or adds SRs that require verification that the Emergency Core Cooling Systems (ECCS), Residual Heat Removal (RHR) System, and Containment Spray (CS) System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed SRs ensure that the subject systems continue to be capable to perform their assumed safety function and are not rendered inoperable due to gas accumulation. Thus, the consequences of any accident previously evaluated are not significantly increased.

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

2. Does the Proposed Change Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated?

Response: No The proposed change revises or adds SRs that require verification that the ECCS, RHR System, and CS System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the Proposed Change Involve a Significant Reduction in a Margin of Safety?

Response: No The proposed change revises or adds SRs that require verification that the ECCS, RHR System, and CS System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change adds new requirements to manage gas accumulation in order to ensure that the subject systems are capable of performing their assumed safety functions. The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected. The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis. Therefore, there are no changes being made to any safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

Page 4 of 5

SBK-L-14024 Therefore, the proposed change does not involve a significant reduction in a margin of safety.

3.2 Applicable Regulatory Requirements/Criteria Based on the above, NextEra concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

5.0 REFERENCES

1. Letter (SBK-L-08179) from G. St. Pierre (FPL Energy Seabrook, LLC) to Document Control Desk (NRC), "Nine Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," October 14, 2008 (ADAMS Accession No. ML082910040)
2. Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," January 11, 2008, (ADAMS Accession No. ML072910759)
3. Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," February 23, 2013, (ADAMS Accession No. ML13053A075)
4. Federal Register Notice of Availability, "TSTF-523, Generic Letter 2008-01 Managing Gas Accumulation Using the Consolidated Line Item Improvement Process" published January 15, 2014 (79 FR 2700).
5. NUREG- 1431, Revision 4, "Standard Technical Specifications -Westinghouse Plants,"

April 2012 (ADAMS Accession No. ML12100A222)

Page 5 of 5

SBK-L-14024 License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 2 Seabrook Station Technical Specifications Changes Marked Up Pages This coversheet plus 8 pages

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 once per 7 days 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% at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

4.4.1.3.3 At least one reactor coolant or RHR loop shall be verified in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

4.4.1.3.4 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.*

1*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. 1 SEABROOK - UNIT 1 3/4 4-5 jAmendment No. I.

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 03- generator water level as soon as possible.

SCn) 0-- a) 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.

= C

.D 0 OU)

= u) 0c SURVEILLANCE REQUIREMENTS Cn

.2 L 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required c shall be determined to be within limits at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

0 4.4.1.4.1.2 At least one RHR loop shall be determined to be in operation and circulating 6 reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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 C-

> other RHR loop is OPERABLE and in operation.

.-- ***A reactor coolant pump shall not be started unless the secondary water temperature of E each steam generator is less than 50°F above each of the Reactor Coolant System cold-leg

. temperatures.

SEABROOK- UNIT 1 3/44-6 iAmendment No. I

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 at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

4.4.1.4.2.1 Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

  • 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 10OF below saturation temperature.

SEABROOK - UNIT 1 3/4 4-7 Amendment No.I

EMERGENCY CORE COOLING SYSTEMS ECCS SUBSYSTEMS - Tava GREATER THAN OR EQUAL TO 350OF 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:

Valve Number 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 CD)

"o RH-V-32 RHR to Hot-Leg Isolation Closed RH-V-70 RHR to Hot-Leg Isolation Closed

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

. Sl-V-102 SI to Hot-Leg Isolation Closed

b. At least once per 31 days by:
1) -Vere*fyng that the EGS piping ifull of watc, and o) 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, E etc.) is present in the containment which could be transported to the (D 0 containment sump and cause restriction of the pump suctions during LOCA co 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.

/SEABROOK - UNIT 1 3/4 5-5 Amendment No. 30,58, 6+

1** Not required to be met for system vent flow paths opened under administrative control. I

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. At least once per 31 dayc by Verf, '"g that

' ach V*v. (manual, power operated, or automati) the flow path that is net looked, sealed, or etheftise INSERT 1 sui d in position-i,, in 'tGcoect po..ition; Next Page

b. By verifying OPERABILITY of each pump when tested pursuant to Specification 4.0.5;
c. At least once per 18 months 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.

INSERT 2 Next Page d. By verifying each spray nozzle is unobstructed following activities that could N 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 eing manually realigned.

SEABROOK - UNIT 1 3/4 6-14 Amendment No. 39, 90, 42 INSERT I

a. At least once per 31 days 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.

INSERT 2

    • Not required to be met for system vent flow paths opened under administrative control.

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 at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

4.9.8.1.1 Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

  • 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.

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 at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

4.9.8.2.1 Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water at least once per 31 days.

  • 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 jAmendment No.

SBK-L-14024 License Amendment Request for Adoption of Technical Specifications Task Force Traveler (TSTF)-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation Attachment 3 Seabrook Station Technical Specifications Bases Changes Marked Up Pages For Information Only This coversheet plus 13 pages

3/4.4 REACTOR COOLANT SYSTEM BASES 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION An OPERABLE reactor coolant system loop consists of an OPERABLE reactor coolant pump and an OPERABLE steam generator.

The plant is designed to operate with all reactor coolant loops in operation and maintain DNBR above 1.30 during all normal operations and anticipated transients. In MODES 1 and 2 with one reactor coolant loop not in operation, this specification requires that the plant be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

In MODE 3, two reactor coolant loops provide sufficient heat removal capability for removing core decay heat even in the event of a bank withdrawal accident; however, a single reactor coolant loop provides sufficient heat removal capacity if a bank withdrawal accident can be prevented, i.e., by placing the Control Rod Drive System in a condition incapable of rod 0 withdrawal. Single failure considerations require that two loops be OPERABLE at all times.

t'-"In MODE 4, and in MODE 5 with reactor coolant loops filled, a single reactor coolant loop V or RHR loop provides sufficient heat removal capability for removing decay heat; but single a.->: failure considerations require that at least two loops (either RHR or RCS) be OPERABLE.

.-h -J In MODE 5 with reactor coolant loops not filled, a single RHR loop provides sufficient 0 rheat removal capability for removing decay heat; but single failure considerations, and the o ci* unavailability of the steam generators as a heat removing component, require that at least two

> W RHR loops be OPERABLE.

(00 A Reactor Coolant "loops filled", condition is defined as follows: (1) Having pressurizer 0 Ea 4-level greater than or equal to 55% if the pressurizer does not have a bubble, and greater than or

.:

  • equal to 17% when there is a bubble in the pressurizer. (2) Having the air and non-
0) W condensables evacuated from the Reactor Coolant System by either operating each reactor c: coolant pump for a short duration to sweep air from the Steam Generator U-tubes into the upper
head area of the reactor vessel, or removing the air from the Reactor Coolant System via an RCS evacuation skid, and (3) Having vented the upper head area of the reactor vessel ifthe pressurizer does not have a bubble. (4) Having the Reactor Coolant System not vented, or if vented capable of isolating the vent paths within the time to boil.

Draining the RCS to a level that is lower than the stated limits (55% with no bubble or 17% with a bubble) and subsequently re-establishing the required levels does not preclude establishing the "loops filled" condition as long as the level is not dropped to the point at which V additional air can be introduced into the steam generator tubes. If no additional air is introduced into the steam generator tubes, the refill of the RCS re-establishes the conditions that existed prior to the draining. Engineering Evaluation EE-08-012 demonstrates that, with the maximum amount of air/gas available from reactor coolant system sources in Mode 5 present in the steam generator tubes, any two steam generators provide adequate decay heat removal via natural circulation approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after shutdown.

SEABROOK - UNIT 1 B 3/4 4-1 Amendm-,ent No. 93, BC 02-02, 07-0-,

3/4.4 REACTOR COOLANT SYSTEM BASES 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION (Continued)

Ifthe RCS is drained to the point where additional air is available to enter the steam generators, i.e., to a reduced inventory condition [E1.(-)36"], then the air/gas must be removed from the steam generator tubes prior to the steam generators being available as a heat sink.

This will require either the removal of the air from the Reactor Coolant System via the RCS evacuation skid or operating each reactor coolant pump for a short duration to sweep air from the Steam Generator U-tubes (only required for those generators to be credited for decay heat removal). Operating the reactor coolant pumps to sweep the loops re-establishes the conditions that existed prior to draining the RCS. Using the evacuation skid results in a larger volume of air/gas contained in the steam generator u-tubes than exists under the initial shutdown conditions, however Engineering Evaluations EE-08-012 demonstrates the natural circulation conditions will be established for this circumstance.

The operation of one reactor coolant pump (RCP) or one RHR pump provides adequate flow to ensure mixing, prevent stratification and produce gradual reactivity changes during boron concentration reductions in the Reactor Coolant System. The reactivity change rate associated with boron reduction will, therefore, be within the capability of operator recognition and control.

The restrictions on starting an RCP in MODES 4 and 5 are provided to prevent RCS pressure transients, caused by energy additions from the Secondary Coolant System, which could exceed the limits of Appendix G to 10 CFR Part 50. The RCS will be protected against overpressure transients and will not exceed the limits of Appendix G by restricting starting of the RCPs to when the secondary water temperature of each steam generator is less than 50°F above each of the RCS cold-leg temperatures.

IINSERT 1 next page I SEABROOK - UNIT 1 B 3/4 4-1 a BG 08 03-

IlNSERT RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

SR 4.4.1.3.4 is modified by a Note that states the SR is 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. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

The 31 day frequency for ensuring locations are sufficiently filled with water takes into consideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation.

3/4.5 EMERGENCY CORE COOLING SYSTEMS BASES 3/4.5.1 ACCUMULATORS The OPERABILITY of each Reactor Coolant System (RCS) accumulator ensures that a sufficient volume of borated water will be immediately forced into the reactor core through each of the cold legs in the event the RCS pressure falls below the pressure of the accumulators. This initial surge of water into the core provides the initial cooling mechanism during large RCS pipe ruptures.

The limits on accumulator volume, boron concentration, and pressure ensure that the assumptions used for accumulator injection in the safety analysis are met.

In MODES 1 and 2, the accumulator power-operated isolation valves are considered to be "operating bypasses" in the context of IEEE Std. 279-1971, which requires that bypasses of a protective function be removed automatically whenever permissive conditions are not met. In MODES 1, 2, 3, and in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entry into MODE 3 from 4, the accumulator isolation valves are open with their power removed whenever pressurizer pressure is greater than 1000 psig. In addition, as these accumulator isolation valves fail to meet single-failure criteria, removal of power to the valves is required.

The limits for operation with an accumulator inoperable for any reason except an isolation valve closed minimizes the time exposure of the plant to a LOCA event occurring concurrent with failure of an additional accumulator which may result in unacceptable peak cladding temperatures. If a closed isolation valve cannot be immediately opened, the full capability of one accumulator is not available and prompt action is required to place the reactor in a mode where this capability is not required.

Managing of gas voids is important 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS to ECCS OPERABILITY.

The OPERABILITY of two independent ECCS subsystems ensures that sufficient emergency core cooling capability will be available in the event of a LOCA assuming the loss of one subsystem through any single-failure consideration. Either subsystem operating in conjunction with the accumulators is capable of supplying sufficient core cooling to limit the peak cladding temperatures within acceptable limits for all postulated break sizes ranging from the double-ended break of the largest RCS cold-leg pipe downward. In addition, each ECCS subsystem provides long-term core cooling capability in the recirculation mode during the accident recovery period. <

Operability of the ECCS flow paths is contingent on the ability of the encapsulations surrounding the containment sump isolation valves (CBS-V8 and CBS-V14) to perform their design functions. During the recirculation phase of an accident, any postulated leakage resulting from the failure of the valves or piping will be contained within the encapsulations, preserving the water inventory needed to support ECCS operation during recirculation.

Consequently, maintaining the encapsulations intact with leakage within allowable limits is necessary to ensure operability of the ECCS flow paths. Although designed to withstand containment pressure, the encapsulations do not function as a containment boundary, but rather prevent the release of radioactive fluid and gasses to the environment.

SEABROOK - UNIT 1 B 3/4 5-1 SBOR No. 02 03, BC 4-4-2, 89-01"

EMERGENCY CORE COOLING SYSTEMS BASES 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS (Continued)

An automatic valve may be aligned in other than its accident position provided (1) the valve receives an automatic signal to re-position to its required position in the event of an accident, and (2) the valve is otherwise operable (stroke time within limits, motive force available to re-position the valve, control circuitry energized, and mechanically capable of re-positioning).

With the exception of the operating centrifugal charging pump, the ECCS pumps a renor ally in a standby, non-operating mode./ ........ , ..... pat pipin h-,,,,

the eling water storage tank (RWST) and from the ECCS recircula sump to the RCS full o-f r (.byverifying at the accessible ECCS piping h' oints and pump casings, excluding erating centrifugal charging p ensures that the system will perform properly, injectingr pum capacity a p ntot non- and. This will alsor, IINSERT 2 next page SEABROOK - UNIT 1 B 3/4 5-2a BCR-N. 02_03, O4-no, 09g()

INSERT 2 ECCS piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the ECCS and may also prevent a water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of ECCS locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS locations susceptible to gas accumulation are monitored and, ifgas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day frequency for SR 4.5.2.b.1) takes into consideration the gradual nature of gas accumulation in the ECCS piping and the procedural controls governing system operation.

Surveillance 4.5.2.b.2) is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent path who is in continuous communication with the operators in the control room. The individual will have a method to rapidly close the system vent flow path if directed.

EMERGENCY CORE COOLING SYSTEMS BASES

--.31I..r,5. .A

. ECCGSUBS,.YST-EMVs (Conqt-',itied) coniin Surveillance Requirement by stating that verification is to be pe datte "accessible" EC iping high points and pump casing, e xcluding theo ing centri~fugal*

charging pump. Thu ases recognizes that certain "impraci i ies," i.e., physical accessibility issues or theop in centrifugal chargin pLonly) under dynamic conditions, may preclude verificatio certain point as such provides relief. However, such relief cannot be taken at the expens ible system inoperability because of lack of periodic verification. Such relief can if there is reasonable assurance that the collection of gasses or void fo ion is of no signi t concern at the points not to be verified periodically within tipulated surveillance interval i. every 31 days).

Furthermore, becau regulatory requirements, even if reas nab surance can be justified for no quring verification at a particular high point, such verifical mustbe perfor the high point is accessible. "Inaccessibility' cannot be used as asm c enience.

ECCS piping high points may be considered inaccessible if any of the following criteria are met:

a) The high point is located inside the bioshield in containment while the reactor is ,

critical (Modes 1 & 2), since this area can contain lethal radiation fields during reactor operation. During those situations when the reactor is not critical, other conditions where gaining access poses a safety or radiological hazard (e.g., high system temperature, high radiological conditions) may prohibit verification by UT/venting.

b) The high point is located in an area where gaining access poses a safety or radiological hazard, e.g.: X

  • Installation/removal of temporary ladders within containment or other areas where stay times (heat stress / high radiation levels) or other factors must be kept to minimums.

Note: The safety or radiological concern should be documented for further evaluation K by the responsible organ izati on (s).

c) High points within heat exchanger tubes.

IV1 I Uf vvate," is sujctv particularly sic most systern fluid9*strearn PI "fulvlu contain a certain non-condensable gasses. ECCS pip!n siered 'full of water" if there is reasonable assu the c e non-condensable gas within the system (including the aggre of non-co asses in all ECCS piping) and at a parti Wi not be of significance to impair the ECCS sys

- mi g*

SEABROOK - UNIT 1 B 3/4 5-3 BCR No. 02 03, 09 01

EMERGENCY CORE COOLING SYSTEMS BASES 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS (Continued) y ven to water hammer, pump cavitation or pumping of non-condensable gas into the re tor ve el following a safety injection (SI) signal or during shutdown cooling.

Other C siderations:

I. Ventin causing ECCS Inoperability - opening a vent valve in an EC S flowpath that will resul both trains of an ECCS sub-system becoming inoper le during the period in wh' h the vent is open such that it cannot be restored uring a design basis accident. Ho ver, verification can be made by other mean e.g., UT.

I1. No makeup water s rce for venting - in the situation where a high point exists between two closed va es and opening a valve to al' n a water source will result in ECCS inoperability, it is n possible to verify the s stem is full since there is no source of water to discharge rom the vent. Ve ng at these locations may in fact induce gasses into the system 'a "gas stripp 'g" as the fluid is depressurized.

However, verification can be ma by oth means e.g., UT.

Ill., High-pressure fluid within system pipi - a vent in a high-pressure system is inaccessible if manipulating the val can ause personnel safety concerns.

However, verification can be ma by other eans e.g., ultrasonic testing (UT).

IV. The TS Bases states, in pa ,that "With the excep n of the operating centrifugal charging pump, the EC pumps are normally in a ndby, non-operating mode. As such, flow path piping as the potential to develop void and pockets of entrained gases." When RH is in its shutdown cooling mode the p ential for development of voids and pocke of entrained gases in flow path piping is, ctically, of no concern.

O bsevation oormal operating parameters/indications of the erating RHR train is suffilicirent ye, Ocation that the piping in the flow path is full of water. However, these portions piping in the RHR train that are stagnant and which are u d for ECCS purpo s would still require verification by other means (e.g. UT, venti to ensure the agnant piping is full of water.

V. f an ECCS high point that is normally monitored becomes inaccessible due to D 94Fnd such as elevated radiation levels, an evaluation may be use s OfMW in conditions, change an interim measure to provide reasonable assurance that the ECCS remains operable. When the high point becomes accessible, verification that the piping is full SEABROOK - UNIT 1 B 3/4 5-4 BCR No. 02-03, G9-9-1

EMERGENCY CORE COOLING SYSTEMS BASES 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS (Continued) j ..... S~hould activities (e.g., mlainlte nla nc e) u , e vents (e.y., flow in'l. ,,ula il.;,',

urization, system leakage) occur that could cause gasses to corn solution or uced into ECCS piping then it may be pr verify the ECCS piping as being full at t o entially affected nts including those high points that are not normally verified, if dee ropriate.

VII. A void dete T would require further investigation to mne its size and e,and the void must either be refilled by purging/venting or evalua Surveillance Requirements for throttle valve position stops and flow balance testing provide assurance that proper ECCS flows will be maintained in the event of a LOCA.

Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to: (1) prevent total pump flow from exceeding runout conditions when the system is in its minimum resistance configuration, (2) provide the proper flow split between injection points in accordance with the assumptions used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injection points equal to or above that assumed in the ECCS-LOCA analyses.

Verifying that the RHR system suction valve interlock is OPERABLE ensures that the RCS will not pressurize the RHR system beyond its design pressure. The value specified in the surveillance requirement ensures that the valves cannot be opened unless the RCS pressure is less than 440 psig.. Due to bistable reset design, and the instrument uncertainty, the valves could be open above the interlock setpoint, but below the reset pressure. To ensure that the RHR system design pressure will not be exceeded, the actual interlock setpoint takes into consideration RHR suction relief valve settings and allowable tolerance, bistable deadband, total instrument channel uncertainty associated with the interlock, and available operating margin (differential pressure operating limit) for reactor coolant pump operation to ensure shutdown cooling can be transitioned to RHR. This results in the actual setpoint and reset values being below the value specified in the surveillance requirement. The actual interlock setpoint and reset values, in addition to separate administrative controls, will ensure that the RHR suction isolation valves cannot be opened from the main control room when the RCS pressure could cause the RHR system design pressure to be exceeded.

3/4.5.4 REFUELING WATER STORAGE TANK The OPERABILITY of the refueling water storage tank (RWST) as part of the ECCS ensures that a sufficient supply of borated water is available for injection by the ECCS in the event of a LOCA. The limits on RWST minimum volume and boron concentration ensure that: (1) sufficient water is available within containment to permit recirculation cooling flow to the core and (2) the reactor will remain subcritical in the cold SEABROOK - UNIT 1 B 3/4 5-5 BCR 02 03, 99--Ot

CONTAINMENT SYSTEMS BASES 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS Managing of gas voids is important to Containment Spray 3/4.6.2.1 CONTAINMENT SPRAY SYSTEM System OPERABILITY.

The OPERABILITY of the Containment Spray System ensures that containment depressurization and cooling capability will be available in the event of a LOCA. The pressure reduction and resultant lower containment leakage rate are consistent with the assumptions used in the safety analyses.

The two independent Containment Spray Systems provide post-accident cooling of the containment atmosphere. The Containment Spray Systems also provide a mechanism for removing iodine from the containment atmosphere, and, therefore, the time requirements for restoring an inoperable Spray System to OPERABLE status have been maintained consistent with those assigned other inoperable ESF equipment.

may water, even w~ith so " e faneau e considered full of the system F-11-1 *qlv,;l~

- #*, .. VC*I JI J ýlI*JIIIII

  • ILO Opeem..ll d safetIl.y Ig chlb l I I.

Verifying the correct alignment of manual, power-operated, and automatic valves provides assurance that the proper flow paths exist for operation of the Containment Spray System under accident conditions. This verification includes only those valves in the direct flow paths through safety-related equipment whose position is critical to the proper functioning of the safety-related equipment. Vents, drains, sampling connections, instrument taps, etc., that are not directly in the flow path and are not critical to proper functioning of the safety-related equipment are excluded from this surveillance requirement.

This surveillance does not apply to valves that are locked, sealed, or otherwise secured in position because these valves are verified in their correct position prior to locking, sealing, or securing. Also, this requirement does not apply to valves that cannot be inadvertently misaligned, such as check valves.

An automatic valve may be aligned in other than its accident position provided (1) the valve receives an automatic signal to re-position to its required position in the event of an accident, and (2) the valve is otherwise operable (stroke time within limits, motive force available to re-position the valve, control circuitry energized, and mechanically capable of re-positioning). INSERT 3 next pagel Surveillance requirement (SR) 4.6.2.1 .d requires verification that each spray nozzle is unobstructed following activities that could cause nozzle blockage. An air or smoke flow test is used to ensure that each spray nozzle is unobstructed and that spray coverage of the\

containment during an accident is not degraded. Normal plant activities are not expected to initiate this SR. However, activities such as inadvertent spray actuation that causes fluid flow through the spray nozzles or a loss of foreign material control when working on the system may require performing the surveillance.

SEABROOK - UNIT 1 B 3/4 6-3 .A.mcnd-mentNo. 14, BC 04-09, 09041 12l-0

INSERT 3 Containment Spray System flow path piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the containment spray trains and may also prevent a water hammer and pump cavitation.

Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The Containment Spray System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Containment Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water),

the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day frequency for SR 4.6.2.1 .a.1) takes into consideration the gradual nature of gas accumulation in the Containment Spray System piping and the procedural controls governing system operation.

Surveillance 4.6.2.1 .a is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing a dedicated individual at the system vent path who is in continuous communication with the operators in the control room. The individual will have a method to rapidly close the system vent flow path if directed.

3/4.9 REFUELING OPERATIONS (Continued)

BASES 3/4.9.5 (THIS SPECIFICATION NUMBER IS NOT USED.)

3/4.9.6 (THIS SPECIFICATION NUMBER IS NOT USED.)

Managing of gas voids is important to RHR System 3/4.9.7 (THIS SPECIFICATION NUMBER IS NOT USED.) OPERABILITY.

3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION The requirement that at least one residual heat removal (RHR) loop be in operation ensures that: (1) sufficient cooling capacity is available to remove decay heat and maintain the water in the reactor vessel below 140'F as required during the REFUELING MODE, and (2) sufficient coolant circulation is maintained through the core to minimize the effect of a boron dilution incident and prevent boron stratification. <

The requirement to have two RHR loops OPERABLE when there is less than 23 feet of water above the reactor vessel flange ensures that a single failure of the operating RHR loop will not result in a complete loss of residual heat removal capability. However, only one RHR loop is required for decay heat removal with water level at least 23 feet above the reactor vessel flange and the upper internals removed from the reactor vessel. The large volume of water above the flange provides backup decay heat removal capability.

When installed in the reactor vessel, the upper internals provide a flow restriction between the core region and the refueling cavity. Consequently, following a loss of RHR cooling, heating of the water in the core would proceed faster than heating of the refueling cavity water, and core boiling could occur in a relatively short period of time. As a result, administrative controls implement compensatory measures to reduce the risk of core boiling should a loss of RHR cooling occur. These administrative controls ensure that the second train of RHR, although not required by the TS to be operable, will be functional within approximately one-half the time to core boiling following a loss of the operable RHR train.

Closure of the Equipment Hatch containment penetration using the Containment Outage Door may satisfy the containment closure requirement of the action statements for Technical Specifications 3.9.8.1 and 3.9.8.2, when the Containment Outage Door is being used during the movement of non-recently irradiated fuel assemblies within containment in lieu of the Containment Equipment Hatch.

INSERT 4 next page SEABROOK - UNIT 1 B 3/4 9-3 BC 04 01, 99 9

RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrument drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walkdowns to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as standby versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR System locations susceptible to gas accumulation are monitored and, ifgas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day frequency for ensuring locations are sufficiently filled with water takes into consideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation.

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