ML15002A251

Unit No.1 - Issuance of Amendment Regarding License Amendment Request 14-06, Application Regarding the Removal of the Cold Leg Injection Permissive from Technical Specifications

ML15002A251
Person / Time
Site:	Seabrook
Issue date:	03/31/2015
From:	John Lamb Plant Licensing Branch 1
To:	Dean Curtland NextEra Energy Seabrook
John Lamb, NRR/DORL 415-3100
References
TAC MF4926
Download: ML15002A251 (17)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 31, 2015 Mr. Dean Curtland, Site Vice President clo Michael Ossing Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT REGARDING LICENSE AMENDMENT REQUEST 14-06, APPLICATION REGARDING THE REMOVAL OF THE COLD LEG INJECTION PERMISSIVE FROM TECHNICAL SPECIFICATIONS (TAC NO. MF4926)

Dear Mr. Curtland:

The Commission has issued the enclosed Amendment No. 145 to Facility Operating License No. NPF-86 for the Seabrook Station, Unit No. 1. This amendment consists of changes to the facility technical specifications (TSs) in response to your application dated September 24, 2014, as supplemented December 11, 2014.

The amendment removes the cold leg injection permissive (P-15) from TS 3.3.2, "Engineered Safety Features Actuation System Instrumentation," and changes License Condition 2.K, "Inadvertent Actuation of the Emergency Core Cooling System (ECCS)."

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

P7~

. Lamb, Senior Project Manager Pl n Licensing Branch 1-2 Di i ion of Operating Reactor Licensing 0 *ce of Nuclear Reactor Regulation Docket No. 50-443

Enclosures:

1. Amendment No. 145 to NPF-86

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NEXTERA ENERGY SEABROOK, LLC. ET AL.*

DOCKET NO. 50-443 SEABROOK STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 145 License No. NPF-86

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by NextEra Energy Seabrook, LLC, et al.,

(the licensee) dated September 24, 2014, as supplemented by letter dated December 11, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

• NextEra Energy Seabrook, LLC is authorized to act as agent for the: Hudson Light & Power Department, Massachusetts Municipal Wholesale Electric Company, and Taunton Municipal Light Plant and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility.

2. Accordingly, the license is amended by changes to paragraphs 2.C.(2) and 2.K of Facility Operating License No. NPF-86, and is hereby amended to read as follows:

2.C.(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 145, and the Environmental Protection Plan contained in Appendix Bare incorporated into the Facility License No. NPF-86.

NextEra Energy Seabrook, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

2.K. Inadvertent Actuation of the Emergency Core Cooling System (ECCS)

Prior to startup from refueling outage 11, FPL Energy Seabrook* commits to either upgrade the controls for the pressurizer power operated relief valves (PORV) to safety-grade status and confirm the safety-grade status and water-qualified capability of the PORVs, PORV block valves and associated piping or to provide a reanalysis of the inadvertent safety injection event, using NRC approved methodologies, that concludes that the pressurizer does not become water solid within the minimum allowable time for operators to terminate the event. NextEra Energy Seabrook, LLC submitted an analysis of the inadvertent safety injection event in a letter dated November 7, 2005. In a letter dated June 9, 2006, the NRC concluded the analysis met the requirements of License Condition 2.K.

• On April 16, 2009, the name "FPL Energy Seabrook, LLC" was changed to "NextEra Energy Seabrook, LLC."

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

• ~~

~ Douglas A. Broaddus, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: March 31, 2015

ATTACHMENT TO LICENSE AMENDMENT NO. 145 FACILITY OPERATING LICENSE NO. NPF-86 DOCKET NO. 50-443 Replace the following pages of Facility Operating License No. NPF-86 with the attached revised pages. The revised pages are identified by amendment number and contains marginal lines indicating the area of change.

Remove 3 3 7 7 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

Remove 3/4 3-21 3/4 3-21 3/4 3-28 3/4 3-28 3/4 3-35 3/4 3-35

(4) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility authorized herein; and (7) DELETED C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level NextEra Energy Seabrook, LLC, is authorized to operate the facility at reactor core power levels not in excess of 3648 megawatts thermal (100% of rated power).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 145*, and the Environmental Protection Plan contained in Appendix Bare incorporated into the Facility License No. NPF-86. NextEra Energy Seabrook, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) License Transfer to FPL Energy Seabrook, LLC**

a. On the closing date(s) of the transfer of any ownership interests in Seabrook Station covered by the Order approving the transfer, FPL Energy Seabrook, LLC**, shall obtain from each respective transferring owner all of the accumulated decommissioning trust funds for the facility, and ensure the deposit of such funds and additional funds, if necessary, into a decommissioning trust or trusts for Seabrook Station established by FPL Energy Seabrook, LLC**, such that the amount of such funds deposited meets or exceeds the amount required under 10 CFR 50. 75 with respect to the interest in Seabrook Station FPL Energy Seabrook, LLC**,

acquires on such dates(s).

• Implemented

• • On April 16, 2009, the name "FPL Energy Seabrook, LLC" was changed to "NextEra Energy Seabrook, LLC".

AMENDMENT NO. 145

J. Additional Conditions The Additional Conditions contained in Appendix C, as revised through Amendment No. 119, are hereby incorporated into this license. NextEra Energy Seabrook, LLC, shall operate the facility in accordance with the Additional Conditions.

K. Inadvertent Actuation of the Emergency Core Cooling System (ECCS)

Prior to startup from refueling outage 11, FPL Energy Seabrook* commits to either upgrade the controls for the pressurizer power operated relief valves

{PORV) to safety-grade status and confirm the safety-grade status and water-qualified capability of the PORVs, PORV block valves and associated piping or to provide a reanalysis of the inadvertent safety injection event, using NRC approved methodologies, that concludes that the pressurizer does not become water solid within the minimum allowable time for operators to terminate the event. NextEra Energy Seabrook, LLC submitted an analysis of the inadvertent safety injection event in a letter dated November 7, 2005. In a letter dated June 9, 2006, the NRG concluded the analysis met the requirements of License Condition 2.K.

3. This license is effective as of the date of issuance and shall expire at midnight on March 15, 2030.

FOR THE NUCLEAR REGULATORY COMMISSION (Original signed by:

Thomas E. Murley)

Thomas E. Murley, Director Office of Nuclear Reactor Regulation Attachments/Appendices:

1. Appendix A - Technical Specifications (NUREG-1386)

2. Appendix B - Environmental Protection Plan

3. Appendix C -Additional Conditions Date of Issuance: March 15, 1990

• On April 16, 2009, the name "FPL Energy Seabrook, LLC" was changed to "NextEra Energy Seabrook, LLC".

AMENDMENT NO. 86, 94, 101, 105, 112, 116, 119, 122, 145

TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION

b. RWST Level--Low-Low 4 2 3 1,2, 3,4 15 Coincident With:

Safety Injection See Item 1. above for all Safety Injection initiating functions and requirements.

9. Loss of Power (Start Emergency Feedwater)

a. 4.16 kV Bus E5 and E6- 2/bus 2/bus 1/bus 1,2, 3,4 14 Loss of Voltage

b. 4.16 kV Bus E5 and E6-Degraded Voltage 2/bus 2/bus 1/bus 1,2,3,4 14 Coincident with SI See Item 1. above for all Safety Injection initiating functions and requirements.

10. Engineered Safety Features Actuation System Interlocks

a. Pressurizer Pressure, P-11 3 2 2 1, 2, 3 19

b. Reactor Trip, P-4 2 2 2 1, 2, 3 21

c. Steam Generator Water 4/stm. gen. 2/stm. gen. 3/stm. gen. 1, 2, 3 18 Level, P-14 SEABROOK - UNIT 1 3/4 3-21 Amendment No. 47. 140, 145

TABLE 3.3-4 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS SENSOR TOTAL ERROR FUNCTIONAL UNIT ALLOWANCE (TA) Z _Jfil_ TRIP SETPOINT ALLOWABLE VALUE

9. Loss of Power (Start Emergency Feedwater)

a. 4.16 kV Bus ES and E6 N.A. N.A. N.A. z 2975 volts z 2908 volts Loss of Voltage with as 1.20 with a s 1. 315 second time second time delay. delay.

b. 4.16 kV Bus E5 and E6 N.A. N.A. N.A. z 3933 volts 2 3902 volts Degraded Voltage with as 10 with as 10.96 second time second time delay. delay.

Coincident with:

Safety Injection See Item 1. above for alt Safety Injection Trip Setpoints and Allowable Values.

10. Engineered Safety Features Actuation System Interlocks

a. Pressurizer Pressure, P-11 N.A. N.A. N.A. ~ 1950 psig ~ 1962 psig

b. Reactor Trip, P-4 N.A. N.A. N.A. N.A. N.A.

c. Steam Generator Water Level, See Item 5. above for all Steam Generator Water Level Trip P-14 Setpoints and Allowable Values.

SEABROOK - UNIT 1 3/4 3-28 Amendment No. 33. 60, 140, 145

TABLE 4.3-2 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS TRIP ANALOG ACTUATING MODES CHANNEL DEVICE MASTER SLAVE FOR WHICH CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION RELAY RELAY SURVEILLANCE FUNCTIONAL UNIT CHECK CALIBRATION TEST TEST LOGIC TEST TEST TEST IS REQUIRED

9. Loss of Power (Start)

Emergency Feedwater)

a. 4.16 kV Bus ES and N.A. SFCP N.A. SFCP N.A. N.A. N.A. 1, 2, 3, 4 E6 Loss of Voltage

b. 4.16 kV Bus ES and N.A. SFCP N.A. SFCP N.A. N.A. N.A. 1, 2, 3, 4 E6 Degraded Voltage Coincident With Safety Injection See Item 1. above for all Safety Injection Surveillance Requirements 10.Engineered Safety Features Actuation System Interlocks

a. Pressurizer N.A. SFCP SFCP N.A. N.A. N.A. N.A. 1, 2, 3 Pressure, P-11

b. Reactor Trip, P-4 N.A. N.A. N.A. N.A. SFCP N.A. N.A. 1, 2, 3

c. Steam Generator SFCP SFCP SFCP N.A. SFCP(1) SFCP( 1) SFCP 1, 2, 3 Water Level, P-14 TABLE NOTATION (1) Each train shall be tested in accordance with the Surveillance Frequency Control Program.

(2) A DIGITAL CHANNEL OPERATIONAL TEST will be performed on this instrumentation.

(3) Setpoint verification is not applicable.

(4) CHANNEL CALIBRATION shall include verification that the time constants are adjusted to the prescribed values.

SEABROOK - UNIT 1 3/4 3-35 Amendment No. 36. 140. 141, 145

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 145 TO FACILITY OPERATING LICENSE NO. NPF-86 NEXTERA ENERGY SEABROOK, LLC SEABROOK STATION. UNIT NO. 1 DOCKET NO. 50-443

1.0 INTRODUCTION

By application dated September 24, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14273A012), as supplemented by letter dated December 11, 2014 (ADAMS Accession No. ML14349A645), NextEra Energy Seabrook, LLC (NextEra or the licensee) requested changes to the technical specifications (TSs) for Seabrook Station, Unit 1 (Seabrook). The amendment removes the cold leg injection permissive (P-15) from TS 3.3.2, "Engineered Safety Features Actuation System Instrumentation," and changes License Condition 2.K, "Inadvertent Actuation of the Emergency Core Cooling System (ECCS)."

The U.S. Nuclear Regulatory Commission (NRC) staff's proposed no significant hazards consideration determination was published in the Federal Register on January 6, 2015 (80 FR 525).

2.0 BACKGROUND

On March 6, 2014 (ADAMS Accession No. ML14029A445), the NRC issued License Amendment No. 140, which revised the Seabrook TS to add a new permissive (P-15) that prevents opening of the high-head safety injection valves until reactor coolant system pressure decreases below the P-15 setpoint. Amendment No. 140 has a 615 day implementation period.

NextEra has not implemented the associated plant design change for P-15.

3.0 REGULATORY EVALUATION

License Condition 2.K, "Inadvertent Actuation of the Emergency Core Cooling System (ECCS),"

states the following:

Prior to startup from refueling outage 11, FPL Energy Seabrook* commits to either upgrade the controls for the pressurizer power operated relief valves (PORV) to safety-grade status and confirm the safety-grade status and water-qualified capability of the PORVs, PORV block valves and associated piping or to provide a reanalysis of the inadvertent safety injection event, using NRC approved methodologies, that concludes that the pressurizer does not become water solid within the minimum allowable time for operators to terminate the event.

• On April 16, 2009, the name "FPL Energy Seabrook, LLC" was changed to "NextEra Energy Seabrook, LLC".

On August 21, 2009, the NRC issued Amendment No. 122 that changed the name "FPL Energy Seabrook, LLC" to "NextEra Energy Seabrook, LLC" (ADAMS Accession No. ML092090391 ).

Inadvertent actuation of the ECCS is a Condition II event that is evaluated for the effects of adding water inventory to the reactor coolant system (RCS). This event could be caused by operator error or by a spurious, automatic actuating signal. Automatic actuation of the ECCS at Seabrook could be caused by a signal from the reactor protection system based on high containment pressure, low pressurizer pressure, or low steamline pressure.

The NRC staff reviewed the sequence of events, the analytical model used for the analyses, the input parameters used in the analytical model, and the results of the transient analyses. The NRC staff's acceptance criteria are based on Title 10 of the Code of Federal Regulations, Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," as follows:

• Criterion 10 - Reactor design. The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.

• Criterion 15 - Reactor coolant system design. The reactor coolant system and associated auxiliary, control, and protection systems shall be designed with sufficient margin to assure that the design conditions of the reactor coolant pressure boundary are not exceeded during any condition of normal operation, including anticipated operational occurrences, and

• Criterion 26-Reactivity control system redundancy and capability. Two independent reactivity control systems of different design principles shall be provided. One of the systems shall use control rods, preferably including a positive means for inserting the rods, and shall be capable of reliably controlling reactivity changes to assure that under conditions of normal operation, including anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable of reliably controlling the rate of reactivity changes resulting from planned, normal power changes (including xenon burnout) to assure acceptable fuel design limits are not exceeded. One of the systems shall be capable of holding the reactor core subcritical under cold conditions.

The acceptance criteria for a Condition II event, such as the inadvertent actuation of the ECCS event, is a reactor trip with the plant being capable of returning to operation. A Condition II event may not propagate to cause a more serious fault (i.e., a Condition Ill or IV event).

Additionally, it may not result in fuel rod failures or in overpressurization of the RCS or secondary system. Specific review criteria for the inadvertent actuation of ECCS event are contained in NUREG 0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Section 15.5.1-2.

4.0 TECHNICAL EVALUATION

Specifically, the proposed change revises the Seabrook TSs as follows:

Modify Tables in TS 3.3.2, "Engineered Safety Features Actuation System Instrumentation," as shown below:

• TS Table 3.3-3, "Engineered Safety Features Actuation System Instrumentation" o Delete Functional Unit 10.d, Cold Leg Injection, P-15

• TS Table 3.3-4, "Engineered Safety Features Actuation System Instrumentation Trip Setpoints" o Delete Functional Unit 10d, Cold Leg Injection, P-15

• TS Table 4.3-2, "Engineered Safety Features Actuation System Instrumentation Surveillance Requirements" o Delete Functional Unit 10d, Cold Leg Injection, P-15 The current License Condition 2.K reads as follows:

Prior to startup from refueling outage 11, FPL Energy Seabrook* commits to either upgrade the controls for the pressurizer power operated relief valves (PORV) to safety-grade status and confirm the safety-grade status and water-qualified capability of the PORVs, PORV block valves and associated piping or to provide a reanalysis of the inadvertent safety injection event, using NRC approved methodologies, that concludes that the pressurizer does not become water solid within the minimum allowable time for operators to terminate the event.

• On April 16, 2009, the name "FPL Energy Seabrook, LLC" was changed to "NextEra Energy Seabrook, LLC".

The proposed change to License Condition 2.K is as follows:

Prior to startup from refueling outage 11, FPL Energy Seabrook* commits to either upgrade the controls for the pressurizer power operated relief valves (PORV) to safety-grade status and confirm the safety-grade status and water-qualified capability of the PORVs, PORV block valves and associated piping or to provide a reanalysis of the inadvertent safety injection event, using NRC

approved methodologies, that concludes that the pressurizer does not become water solid within the minimum allowable time for operators to terminate the event. NextEra Energy Seabrook, LLC submitted an analysis of the inadvertent safety injection event in a letter dated November 7, 2005. In a letter dated June 9, 2006, the NRC concluded the analysis met the requirements of License Condition 2.K.

• On April 16, 2009, the name "FPL Energy Seabrook, LLC" was changed to "Next Era Energy Seabrook, LLC".

When the ECCS is actuated, the reactor is tripped and borated water is pumped from the refueling water storage tank by the centrifugal charging pumps into the cold leg of each RCS loop. The safety injection (SI) pumps are also started; however, they cannot deliver flow until the shutoff head of these pumps is lower than the nominal RCS pressure. Since the initiating event also causes a reactor shut down, the inadvertent actuation of the ECCS is not expected to result in any fuel rod failures. Additionally, since the charging pumps have a shutoff head of 2600 pounds per square inch atmospheric (psia), they cannot pressurize the RCS to pressures exceeding 11 O percent of RCS design pressure (2750 psia). The reactor trip also prevents the development of a significant power-load mismatch, such that the event will not result in an overpressurization of the secondary system.

The ECCS is, however, capable of filling the pressurizer and causing the discharge of water through the PORVs or the pressurizer safety-relief valves (PSRVs). If these valves are not qualified for water relief, they are assumed, in accident analyses, to stick open and create a small-break loss-of-coolant-accident (LOCA) at the top of the pressurizer (a Condition Ill event).

This would be a violation of the Condition II acceptance criterion, which prohibits a Condition II event from developing into a more serious (Condition Ill or IV) event.

Operator action is required to terminate SI flow to prevent filling the pressurizer and actuating the pressurizer power-operated relief and safety valves, so that this Condition II event does not propagate to a more serious plant condition. The Seabrook analysis for inadvertent operation of the ECCS credits operator action to stop all but one centrifugal charging pump at 9 minutes after the beginning of the event, and to terminate all charging flow at 13 minutes into the event based on analyzed maximum fill rate. NextEra confirmed the timing for all operator actions assumed in the analysis through time studies on the plant simulator in September and October 2005. NextEra provided its analysis of the inadvertent SI event to the NRC, which indicates that at no time does the pressurizer become water-solid, by letter dated November 7, 2005 (ADAMS Accession No. ML053140139), as supplemented by letters dated January 11, 2006 (ADAMS Accession No. ML060190542), and April 20, 2006 (ADAMS Accession No. ML061150281).

By letter dated June 9, 2006 (ADAMS Accession No. ML061460136), the NRC found that the analysis submitted by the licensee met the requirements described in License Condition 2.K.

The NRC staff completed its review of the submitted information and analysis, and concluded that it adequately demonstrates that an inadvertent actuation of the ECCS would not fill the pressurizer prior to Seabrook plant operators securing the event.

On March 6, 2014, the NRC issued License Amendment No. 140, which has a 615 day implementation period. Amendment No. 140 allows a change to the Seabrook TSs to add a new permissive P-15 for cold leg injection that would delay automatic opening of the cold leg, high-head SI valves on a SI actuation until RCS pressure decreased below the P-15 setpoint.

The change was proposed to increase the time available for the operators to terminate an inadvertent SI actuation. The analysis of an inadvertent operation of the ECCS during power operation credits operator action to terminate SI flow within prescribed time limits.

NextEra manages Seabrook time-critical operator actions in accordance with a Seabrook Station administrative procedure SM 7.20, "Control of Time Critical Actions and Operator Response Times." Administrative controls ensure that: (1) time-critical actions (TCAs) are identified; (2) TCAs can be accomplished by plant personnel; and (3) periodic validation of TCAs are documented. The procedure requires that the operators demonstrate the ability to complete TCAs within 80 percent of the time required to complete the critical task. NextEra periodically monitors performance in completing TCAs in accordance with the Seabrook time critical actions program. If operator performance does not maintain a 20 percent margin for completing TCAs, the condition is entered in the corrective action program, and NextEra initiates actions to improve performance. Procedure SM 7.20 requires the following to terminate SI following an inadvertent SI:

• Interval between SI actuation and stopping one centrifugal charging pump - 9 minutes, and

• Interval between the pressurizer reaching 95 percent and stopping all charging pumps -

13 minutes.

Updated Final Safety Analysis Report (UFSAR) Section 15.5.1, "Inadvertent Operation of Emergency Core Cooling System during Power Operation," states the following:

The analysis credits heat removal through the steam generators using the atmospheric steam dump valves, stopping of all but one centrifugal charging pump at 9 minutes after the beginning of the event, and termination of all charging flow at 13 minutes into the event based on analyzed maximum fill rate.

The results of the revised analysis indicate that at no time does the pressurizer become water-solid.

NextEra has not implemented the associated plant design change for P-15, and it has decided not to proceed with the P-15 design change. NextEra stated the following the reason for not wanting to install the P-15 modification:

A review of activities related to installation of the design change for permissive P-15 raised concerns based on the extent of intrusive activities required to install the design change. The field work would occur in cabinets in the control room containing wire bundles with hundreds of leads and terminations. Many of these wire terminations have remained undisturbed since initial installation. While the P-15 design change itself would have no adverse effect on plant systems and components, the activities involved in installing the design change could potentially disturb other wiring in the control room cabinets that could have an

adverse effect on plant operation. An inadvertent, unrecognized dislocation or disconnection in the numerous wiring configurations could result in a system or component malfunction that may not become apparent until the plant attains operation at power.

The NRC staff has reviewed the information provided in the submittal including the analysis provided in the letter dated November 7, 2005, as supplemented by letters dated January 11, 2006, and April 20, 2006. In a letter dated June 9, 2006, the NRC staff found that:

... the reanalysis was performed using methods, assumptions, and operator time responses acceptable to the NRC staff. The results of this revised analysis indicate that the inadvertent ECCS actuation event would not fill the pressurizer before plant operators could terminate the event. Thus, the inadvertent ECCS actuation event is not expected to result in water relief through the pressurizer PORVs or PSRVs that could potentially lead to a more serious Condition Ill event. Therefore, the NRC staff finds that the reanalysis submitted by [the licensee] FPLE satisfies the requirements of License Condition 2.K.

The NRC staff finds that the removal of the P-15 permissive from TS 3.3.2 is acceptable, and the change to License Condition 2.K is acceptable.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New Hampshire and Massachusetts State officials were notified of the proposed issuance of the amendment. The State officials provided no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (80 FR 525, January 6, 2015). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: J. Lamb Date: March 31 , 2015

ML15002A251 *via email OFFICE LPL 1-2/PM LPL 1-2/LA STSB/BC OGG- NLO LPL 1-2/BC LPL 1-2/PM DBroaddus NAME JLamb ABaxter RElliott BMizuno (REnnis for) JLamb DATE 12/30/2014 02/11/2015 01/08/2015 02/13/2015 03/31/2015 03/31/2015