JAFP-07-0091, Application for Technical Specifications Change Based on TSTF-477, Add Action Statement for Two Inoperable Control Room Air Conditioning Subsystems, Using the Consolidated Line Item Improvement Process (CLIIP)

Application for Technical Specifications Change Based on TSTF-477, Add Action Statement for Two Inoperable Control Room Air Conditioning Subsystems, Using the Consolidated Line Item Improvement Process (CLIIP)

ML072130164
Person / Time
Site:	FitzPatrick
Issue date:	07/25/2007
From:	Peter Dietrich Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-07-0091, TSTF-477, Rev 3
Download: ML072130164 (19)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP Entergy P.O. Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 Pete Dietrich Site Vice President - JAF July 25, 2007 JAFP-07-0091 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Application for Technical Specifications (TS) Change Based on TSTF-477, Add Action Statement for Two Inoperable Control Room Air Conditioning Subsystems. Using the Consolidated Line Item Improvement Process (CLIIP)

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) hereby requests an amendment to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant.

The proposed amendment would modify the TS by adding an Action statement for two inoperable control room air conditioning (AC) subsystems to the TS, consistent with NRC approved Industry/Technical Specifications Task Force (TSTF)-477, Revision 3.

Attachment 1 provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications.

Attachment 2 provides the existing TS pages marked-up to show the proposed changes.

Attachment 3 provides revised, clean TS pages (re-typed).

Attachment 4 provides the existing TS Bases pages marked-up to show the proposed changes. The Bases changes are provided for information only. The final TS Bases pages (revised, clean pages) will be submitted with a future update in accordance with TS 5.5.11, "Technical Specifications (TS) Bases Control Program."

ENO requests approval of the proposed License Amendment by July 1, 2008, with the amendment being implemented within 60 days from the date of approval.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated New York State Official.

There are no new commitments made in this letter. If you have any questions, please contact Mr. Jim Costedio, Regulatory Compliance Manager at 315-349-6358.

(t40D

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

Executed on the day qp-YfJly, 2007 Pete Dietrich Site Vice President PD/tp Attachments: 1. Description and Assessment

2. Proposed Technical Specification Pages (Marked-Up)

3. Proposed Technical Specification Pages (Re-Typed)

4. Proposed Technical Specification Bases Pages (Marked-Up) cc:

Mr. Samuel J. Collins USNRC Resident Inspector Regional Administrator, Region I James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission P.O. Box 136 475 Allendale Road Lycoming, NY 13093-0136 King of Prussia, PA 19406-1415 Mr. John P. Boska, Project Manager Mr. Paul Eddy Plant Licensing Branch I-1 New York State Department of Division of Operating Reactor Licensing Public Service Office of Nuclear Reactor Regulation 3 Empire State Plaza, 1 0 th Floor U.S. Nuclear Regulatory Commission Albany, NY 12223 Mail Stop O-8-C2 Washington, DC 20555 Mr. Peter R. Smith, President NYSERDA 17 Columbia Circle Albany, NY 12203-6399 2

Attachment 1 to JAFP-07-0091 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 DESCRIPTION AND ASSESSMENT

Attachment 1 to JAFP-07-0091 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333

1.0 DESCRIPTION

The proposed amendment would modify the Technical Specifications (TS) by adding an Action statement to the Limiting Condition for Operation (LCO) for TS 3.7.4, Control Room Air Conditioning (AC) System. The new Action statement allows a finite time to restore one control room AC subsystem to operable status (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) and requires verification that control room temperature remains < 104 OF every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The licensing basis control room air temperature for the James A. FitzPatrick Nuclear Power Plant (JAFNPP) is 104 OF (References 3 and 4).

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specifications Task Force (TSTF)-477 Revision 3. The availability of this TS improvement was published in the FederalResister on March 26, 2007 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of TSTF-477 and Published Safety Evaluation Entergy Nuclear Operations, Inc. (ENO) has reviewed TSTF-477 (Reference 1), and the NRC model safety evaluation (Reference 2) as part of the CLIIP. ENO has concluded that the information in TSTF-477, as well as the SE prepared by the NRC staff are applicable to JAFNPP and justify this amendment for the incorporation of the changes to the JAFNPP TS.

2.2 Optional Changes and Variations ENO is not proposing any variations or deviations from the TS changes described in TSTF-477 or the NRC staff's model safety evaluation published in the Federal Register on December 18, 2006.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination ENO has reviewed the proposed no significant hazards consideration determination (NSHC) published in the FederalRegister as part of the CLIIP. ENO has concluded that the proposed NSHC presented in the FederalRegister Notice is applicable to JAFNPP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on March 26, 2007 (72 FR 14143) for this TS improvement, ENO verified that the information in TSTF-477, as well as the SE prepared by the NRC staff are applicable to JAFNPP.

Page 1 of 2

Attachment 1 to JAFP-07-0091 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 ENO has proposed changes to the TS Bases consistent with TSTF-477 which provide guidance and details on how to implement the new requirements. JAFNPP has a TS Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS). Specifically, the JAFNPP program is contained in TS 5.5.11, "Technical Specifications (TS) Bases Control Program."

There are no commitments made in this proposed amendment.

4.0 ENVIRONMENTAL EVALUATION The amendment changes requirements with respect to the 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 adopting TSTF-477, Revision 3, 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 TSTF-477, Revision 3, involves no significant hazards considerations, and there has been no public comment on the finding in FederalRegister Notice 71 FR 75774, dated December 18, 2006. 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 be prepared in connection with the issuance of the amendment.

5.0 REFERENCES

1. TSTF-477, Revision 3, Add Action Statement for Two Inoperable Control Room Air Conditioning Subsystems.

2. NRC Model Safety Evaluation, FederalRegister Notice 71 FR 75774, dated December 18, 2006.

3. TS Bases 3.7.4, Control Room Air Conditioning (AC) System.

4. UFSAR Section 9.9.3.11, Control and Relay Room Air Conditioning Systems.

Page 2 of 2

Attachment 2 to JAFP-07-0091 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 PROPOSED TECHNICAL SPECIFICATION PAGES (MARKED-UP)

TS PAGES 3.7.4-1 Insert 1 page 3.7.4-2 3.7.4-3

Control Room ACSystem 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Two control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1. 2. and 3.

During movement of recently irradiated fuel assemblies in the secondary containment.

During operations with a potential for draining the reactor vessel (OPDRVs).

A(rFTnNr CONDITION REQUIRED ACTION COMPLETION TIME A. One control room AC A.1 Restore control room 30 days subsystem inoperable. AC subsystem to OPERABLE status.

)

Required Action and Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (

associated Completi oj",

Time of Condition AND I not met in MODE 1.2.

or 3. Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

!2

\ rý'IJSEPRr I1 (continued)

JAFNPP 3.7.4-1 Amendment

INSERT 1 I r B. Two control room AC B.1 Verify control room area Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> subsystems inoperable. temperature

< 104 OF.

AND B.2 Restore one control room 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AC subsystem to OPERABLE status.

Control Room ACSystem 3.7.4

) ACTTONS (rnntinij~e1'~

CONDITION REQUIRED ACTION ICOMPLETION TIME r.# Required Action and -...-.--...

-NOTE ------------- I associated Completion LCO 3.0.3 is not applicable.

Time of Condition A not met during I movement of recently -P1lace OPERABLE Immediately irradiated fuel !0)1 rnntrnl rrem A(r assemblies in the subsystem in secondary containment operation.

or during OPDRVs.

OR Suspend movement of Immediately I recently irradiated fuel assemblies in the secondary conta i nment.

AND Initiate action to Immediately suspend OPDRVs.

t p Icniud (continued)

,jAFNPP 3.7.4-2 Amendment 76-

Control Room AC System 3.7.4 ArTTA1U'Z (rnnfiniawl)

CONDITION REQUIRED ACTION COMPLETION TIME E. -Two control roor AC ------------ NOTE -------------

subsystem-I during movement of

~eib recently irradiated LCO 3.0.3 is not applicable.

I fuel assemblies in the E.1 Suspend movement of Immediately secondary containment recently irradiated or during OPDRVs. fuel assemblies in the secondary containment.

o-%:ciA-ed opl~' AND T~Of caJ&t4k~ 93 E.2 Initiate action to Immediately na& WPi-eT suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has 24 months the capability to remove the assumed heat load.

JAFNPP 3.7.4-3 JAFNPP.7.4.3Amendmen

Attachment 3 to JAFP-07-0091 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 PROPOSED TECHNICAL SPECIFICATION PAGES (RE-TYPED)

TS PAGES 3.7.4-1 3.7.4-2 3.7.4-3

Control Room AC System 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Control Room Air Conditioning (AC) System LCO 3.7.4 Two control room AC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control room AC A.1 Restore control room AC 30 days subsystem inoperable, subsystem to OPERABLE status.

B. Two control room AC B.1 Verify control room area Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> subsystems inoperable, temperature

< 104 OF.

AND B.2 Restore one control 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> room AC subsystem to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> I associated Completion I Time of Condition A or B AND not met in MODE 1, 2, or I

3. C.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

JAFNPP 3.7.4-1 Amendment

Control Room AC System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and ------------ NOTE--------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A not met during movement of recently irradiated fuel D.1 Place OPERABLE Immediately assemblies in the control room AC secondary containment or subsystem in during OPDRVs. operation.

OR D.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

AND D.2.2 Initiate action to Immediately I suspend OPDRVs.

E. Required Action and ------------ NOTE--------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition B not met during movement of recently irradiated fuel E.1 Suspend movement of Immediately assemblies in the recently irradiated fuel secondary containment or assemblies in the during OPDRVs. secondary containment.

AND E.2 Initiate action to Immediately suspend OPDRVs.

JAFNPP 3.7.4-2 Amendment

Control Room AC System 3.7.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify each control room AC subsystem has the 24 months capability to remove the assumed heat load.

JAFNPP 3.7.4-3 Amendment

Attachment 4 to JAFP-07-0091 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 PROPOSED TECHNICAL SPECIFICATION BASES PAGES (MARKED-UP)

TS BASES PAGES B 3.7.4-3 Bases Insert 1 page B 3.7.4-4 B 3.7.4-5

Control Room AC System B 3.7.4 BASES APPLICABILITY a. During operations with a potential for draining the (continued) reactor vessel (OPDRVs); and

b. During movement of recently irradiated fuel assemblies in the secondary containment. Due to radioactive decay, the Control Room AC system is only required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied art of a critical reactor core within the previous 96 ours).

ACTIONS A.1 With one control room AC subsystem inoperable, the inoperable control room AC subsystem must be restored to OPERABLE status within 30 days. With the plant in this condition, the remaining OPERABLE control room AC subsystem is adequate to perform the control room air conditioning function. However, the overall reliability is reduced because a single active component failure in the OPERABLE subsystem could result in loss of the control room air conditioning function. The 30 day Completion Time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining subsystem can provide the required protection, and the availability of alternate safety and nonsafety cooling methods.

Xtf9Z JL XK.1 and .2 In MODE 1, 2, or 3. if the inoperable control room AC subsystem cannot be restored to OPERABLE status within the associated Completion Time, the plant must be placed in a MODE that minimizes risk. To achieve this status, the plant must be placed in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

LCO 3.0.3 is not applicable while in MODE 4 and 5. However, since recently irradiated fuel assembly movement can occur in MODES 1, 2, or 3 the Required Actions of Condition are,-'J modified by a Note indicating that LCO 3.0.3 does not apply.

(continued)

JAFNPP B 3.7.4-3 Revisiont/

BASES INSERT 1 B.1 and B.2 If both control room AC subsystems are inoperable, the Control Room AC System may not be capable of performing its intended function. Therefore, the control room area temperature is required to be monitored to ensure that temperature is being maintained low enough that equipment in the control room is not adversely affected. With the control room temperature being maintained within the temperature limit, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to restore a control room AC subsystem to OPERABLE status. This Completion Time is reasonable considering that the control room temperature is being maintained within limits and the low probability of an event occurring requiring control room isolation.

Control Room AC System B 3.7.4 BASES

p -D ACTIONS e.1,A.2.1 and '.2.2 (continued)

If moving recently irradiated fuel assemblies while in MODE 1, 2. or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE control room AC subsystem may be placed immediately in operation. This action ensures that the remaining subsystem is OPERABLE, that no failures that would prevent actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action'.1) is to immediately suspend activities that present a 'pOtential for releasing radioactivity that might require isolation of the control room. This places the plant in a condition that minimizes risk.

If applicable, movement of recently irradiated fuel _2 assemblies in the secondary containment must be suspended immediately. Suspension of this activity shall not preclude -*

completion of movement of a component to a safe position.

Also, if applicable, action must be initiated immediately to suspend OP DRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended.

(2,If both coiol room AC systems are no erable or 3 *~e Control J*~AC System~m be capain _of 1, prf ~ing the int m~ed function. herefore, L Y.0.3 must ntered imme tely.

E.1 and E.2 LCO 3.0.3 is not applicable when in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1. 2, or 3 the Required Actions of Condition E are modified by a Note indicating that LCO 3.0.3 does not apply.

(continued)

JAFNPP B 3.7.4-4 Revision,,/

Control Room AC System B 3.7.4 BASES ACTIONS E.1 and E.2 (continued)

If moving recently irradiated fuel assemblies while in MODE 1. 2. or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not a sufficient reason to require a reactor shutdown.

During movement of recently irradiated fuel assembli.es i.n the se conta* or during 01,)~

_6 V-1-71 I rIawe,- action must beTakn .+-*

CAL,-^^ be- m i l--I+ ate1d-y s ivi ies that present a potential Sfor releasing radioactivity that might require isolation of the control room. This places the plant in a condition that I minimizes risk.

If applicable, handling of recently irradiated fuel in the -

secondary containment must be suspended immediately.

Suspension of this activity shall not preclude completion of .,

movement of a component to a safe position. Also, if applicable, action must be initiated immediately to suspend OPDRVs to minimize the probability of a vessel draindown and subsequent potential for fission product release. Action must continue until the OPDRVs are suspended.

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the heat removal capability of the system is sufficient to remove the control room heat load assumed in the safety analyses with ESW providing water to the cooling coils of the air handling units. The SR consists of a combination of testing and calculation. It is acceptable to perform the test using chilled water as the cooling medium to the cooling coils, but a calculation must be performed to ensure that the heat load can be removed with ESW at 85 0 F. The 24 month Frequency is appropriate since significant degradation of the Control Room AC System is not expected over this time period.

REFERENCES 1. UFSAR, Section 9.9.3.11.

2. 10 CFR 50.36(c)(2)(ii).

JAFNPP B 3.7.4-5 Revision/