JAFP-99-0208, Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl

Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl

ML20210C478
Person / Time
Site:	FitzPatrick
Issue date:	07/14/1999
From:	Michael Colomb POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JAFP-99-0208, NUDOCS 9907260073
Download: ML20210C478 (7)

Text

. . J:mes A, FitzP trick Nucle r Pow;r Plant 268 Lake Road P.O. Box 41 Lycoming, New York 13093 1 l

315542-3840 4 NewYorkPbwer uichaei J. coiome

& Authority Site Executive Officer July 14,1999 JAFP-99-0208 United States Nuclear Regulatory Commission j Attn: Document Ccntrol Desk l Mail Station P1-137 Washington, DC 20555-0001

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59 Clarification of Information Hegarding Proposed improved Technical Specifications j

References:

1. NRC Summary of April 14,1999, Meeting Regarding Proposec' improved Technical Specifications (TAC NO. MA5049)(dated May 4,1999)

2. NYPA letter JPN-99-018 (dated June 1,1999) Concerning Revision to Proposed Technical Specification Changes Regarding Conversion to Improved Standard Technical Specifications

Dear Sir:

This letter and the associated attachment is provided to r%vncile differences in information contained in attachments to References 1 and 2.

On April 14,1999, New York Power Authority (NYPA) personriel met with Nucleas Regulatory Commission (NRC) Staff personnel to discuss proposed improved Technical Specifications (ITS) for the FitzPatrick plant which were submitted to the NRC on March 31,1999. As part of the meeting to discuss the proposed ITS, NYPA provided a list of '

ITS items which were then considered to be beyond the current Technical Specifications and outside the standard ITS. These changes, which are commonly referred to as "beyond-beyond" (or "beyond-scope") changes, were discussed and a copy of the beyond- Od beyond handout provided by NYPA was subsequently included as an enclosure to the NRC summary of the April 14,1999, meeting (Reference 1).

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9907260073 990#14 PDR ADOCK 050v03 3 P

260023 e

Unit:d Stit s Nucirr R:gulttrry C mmissien Attn: Document Control Desk

Subject:

Clarification of information Regarding Proposed Improved Technical Specifications Page During the April 14,1999, meeting it was noted that some additionalinformation regarding the beyond-beyond changes should be provided to the NRC to facilitate review of the proposed ITS. NYPA verbally committed to provide the additionalinformation and included the information in Attachment 2 to the June 1,1999 letter (Reference 2) in the form of a revision of the beyond-beyond handout provided at the April 14 meeting and as enclosed l with the May 4,1999 NRC meeting summary. The additional information provided in the attachment revised, supplemented, ordeleted information contained in the handout originally provided at the April 14 meeting without providing an explanation of the differences.

The attachment to this letter provides an explanation (reconciliation) of the differences l between the contents of the attachments to References 1 and 2 and also provides information on two additional topics which are not addressed in Reference 1 or 2, but have been discussed during telephone conversations between NRC and NYPA personnel. These additional topics have been addressed in the attachment because they could be considered by some personnel to be changes that are beyond simple conversion to ITS. These additional topics concern the use of " Allowable Values" (AVr) in ITS (in place of " nominal trip setpoints" (NTSPs) in the CTS) and changes to the ITS Required Actions associated with inoperable excess flow check valves (EFCVs) on instrumentation sensing lines.

If you have questions concerning this matter please contact Mr. G. Tasick at (315) 349-6572.

Very Truly Yours, l .spo Michael J. Colomb Site Executive Officer MJC:VC:las Attachment Cc: Next page

y . .

l cc: Regional Administrator U. S. Nuclear Regulatory Commission l

475 Allendale Road

! King of Prussia, PA 19406 l Office of the Resident inspector c; U. S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Mr. G. Vissing, Project Manager

. Project Directorate l Division of Licensing Project Management U. S. Nuclear Regulatory Commission Mail Stop 8C2 Washington, DC 20555

. Att:: chm:nt 1

. Page 1 of 4 The table below contains each of the items identified in the enclosure to the May 4,1999, NRC summary of the April 14,1999 meeting (first column), the items identified in Attachment 2 to the June 1,1999, NYPA letter (second column), and remarks to reconcile the differences in the first and second columns are in the third column.

The last two items in the table provide information or clarification concerning topics (which could be considered by some personnel to be beyond the scope of a simple conversion to ITS) that were not addressed in either the May 4,1999, NRC summary of the April 14, 1999, meeting or the June 1,1999, NYPA letter.

Items in 4/14/99 Items in 6/1/99 NRC Meetina Summary NYPA Letter Attachment Remarks 3.0.3, JFD X2 3.0.3, JFD X2 Minor changes to text. Text provided in Attachment 2 to the 6/1/99 NYPA letter should be used. 3.3.1.1, ,

CLB11 addresses same topic.  !

l 3.3.1.1, L9 3.3.1.1, L9 None (None) 3.3.1.1, CLB11 Same topic as 3.0.3, JFD X2 (this item is actually an example of "other specifications" refered to in 3.0.3, JFD X2 of the May 4, 1999, NRC meeting summary enclosure).

3.3.5.1, L1 3.3.5.1, L1 and L5 Changes to text to make it clear that the ADS timer is also addressed. Added reference to L5 l for clarification. Changes addressed in L1 and L5 should j be reviewed together as the L1 changes support the L5 changes.

(None) 3.3.5.1, L5 This item added in the June 1, 1999, NYPA letter, attachment 2. The item should be reviewed along with 3.3.5.1, L1 as the timer AVs and tolerances have been changed (L1) to allow the CAllBRAT.ON to be extended to 24 months (L5).

3.4.9, L2 3.4.9, L2 None

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. Attschmrnt 1

. Page 2 of 4 Items in 4/14/99 Items in 6/1/99 NRC Meetina Summarv NYPA Letter Attachment Remarks 3.5.1, L7 3.5.1, L7 ';hanges made to text to make it clear that only HPCI and LPCI flows are being changed.

Editorial errors refered to in the May 4,1999, NRC meeting summary enclosure were determined to be a typographic error that was corrected in the June 1, 1999, NYPA letter Attachment 2 and Revision B to the ITS submittal. Text provided in in June 1 letter attachment should be used. In addition, this item is the same topic as 3.5.2, L5 and both should be reviewed together.

i 3.5.2, L5 3.5.2, L5 Changed text to make clear that only LPCI flow change is being addressed. This item and 3.5.1, L7 address the same topic and should be reviewed together.

3.6.1.9, LS 3.6.1.9, L5 Changes to text made to provide concise examples of consistent Completion Times as verbally requested by l NRC at the April 14,1999, meeting. This item addresses i the same topic as 3.6.2.3, I L4 and both should be reviewed together.

3.6.2.3, L4 3.6.2.3, L4 Changes to text made to provide concise examples of consistent Completion Times as verbally requested by NRC at April 14,1999, meeting. This item addresses the same % w 3.6.1.9, L5 and tub shouid be 2

reviewed togM!w.

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Attschmtnt 1 Page 3 of 4 Items in 4/14/99 Items in 6/1/99 NRC Meetina Summary NYPA Letter Attachment Remarks 3.8.1, M5 and 3.8.1, M5 and The "12" hours in the second JFD CLB6 JFD CLB6 line of the text should be changed to "36" hours as indicated by the hand written markup on the text of the enclosure to the NRC summary of the April 14,1999 meeting.

3.8.4, L2 (None) Item deleted from the June 1, 1999, NYPA letter Attachment 2, because the same topic is addressed in TSTF Generic Change Traveler 202, Since TSTF-202 addresses the same topic this change is not considered to be a "beyond-beyond" or "beyond-scope" change.

l 3.8.4, L4 3.8.4, M2 and L4 Added reference to M2 and made minor changes to the text for clarity.

3.8.6, L1 (None) Item deleted from the June 1, 1999, NYPA letter Attachment 2, because the same topic is addressed in TSTF Generic Change Traveler 202. Since TSTF-202 addresses the same topic this change is not ,

considered to be a "beyond- I beyond" or "beyond-scope" change.

5.5, L2 5.5, L2 Made minor changes to the text for clarity.

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1 Att:chmInt 1 Page 4 of 4 l

Items in 4/14/99 Items in 6/1/99 l NRC Meetina Summarv NYPA Letter Attachment Remarks l RETS (None) Item deleted from the June 1, _

Relocation 1999, NYPA letter Attachment

2. RETS Specifications were  !

evaluated against the 10 CFR l 50.36 screening criteria.

Only those RETS specifications concerning Primary Containment and Secondary Containment f isolation functions met one or more of the 50.36 criteria and those were retained in ITS.

(None) (None) Allowable Values (AVs) are used in ITS in place of nominal trip setpoints (NTSPs) which are used in CTS. The proposed change from NTSPs (used in CTS) to AVs (used in ITS) are discussed the l following ITS:

3.3.1.1, A19; 3.3.2.2, A6; 3.3.4.1, A7; 3.3.5.1, A12; 3.3.5.2, A9; 3.3.6.1, A16; 3.3.6.2, A12; 3.3.7.1, A2; 3.3.7.2, A14; 3.3.8.1, L1; 3.3.8.2, A3 (None) (None) ITS 3.6.1.3 reflects changes to the Required Actions in NUREG-1433, Revision 1, for l excess flow check valve (EFCV) inoperability. NUREG-1433, Required Action C.1 addresses inoperable EFCVs and has a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time. NYPA proposed to address inoperable EFCVs under ITS 3.6.1.3, Required Action A.1 and to maintain the Completion Time at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (consistent with the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in NUREG-1433, Required Action C.1). This change is discussed in ITS 3.6.1.3, NUREG markup JFD DB2.