JPN-96-055, Documents Commitments Re Analyses at Power Uprate Conditions
| ML20138G719 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/23/1996 |
| From: | William Cahill POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| JPN-96-055, JPN-96-55, NUDOCS 9701020221 | |
| Download: ML20138G719 (5) | |
Text
.
123 Mmn Street WNte,Piains New York 10601 914-081-6840 s
914-287 3309 (FAX) i William J. Cahill. Jr.
4# Authority c- ~~ m-l December 23,1996 JPN-96-055 I
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 l
Washington, DC 20555 1
SUBJECT:
James A. FitzPatrick Nuclear Power Plant l
Docket No. 50-333 Additional Information Regarding Analyses at Power Vorate Conditions t
REFE".dNCES:
See below
Dear Sir:
~
i This letter summarizes commitments made by the Authority as a result of recent telephone conversations with the NRC staff. It also documects a new analysis completed by the l
Authority regarding the availability of SRVs for a fire in six plant Fire Areas, and whether
{
l associated procedure changes are necessary.
Recent discussions with the NRC focused on severalissues associated with radiological consequence analyses prepared in support of Technical Specification changes for power i
uprate at FitzPatrick. As a result of these discussions, the Authority agreed to document four i
i commitments: (1) The Authority will conduct additional charcoal adsorber testing of the Control l
Room Emergency Ventilation System filters;(2) The acceptance criteria for the Standby Gas l
Treatment System charcoal filters will be changed from 1% to 0.175% penetration; (3) The j
l FitzPatrick FSAR will be revised to correctly reflect the FitzPatrick Fuel Reliability Action Plan; and (4) The FitzPatrick Emergency Action Levels (EALs) will be updated to reflect the new lower limits on reactor coolant system (RCS) activity levels. These commitments are detailed below.
Emergency Control Room Ventilation System Charcoal Testing l
Section 4.11.A.1.d of the FitzPatrick Technical Specifications require that a sample of charcoal l
from the Main Control Room Ventilation System fresh air filter trains be analyzed once a year j
to assure halogen removal efficiency of at least 99.5 percent. During the next scheduled test,.
the Authority will conduct this test at two relative humidity levels: 70 percent and 95 percent.
The sample tested at 70 percent relative humidity will be used to fulfill the testing requirements of Section 4.11.A.1.d. Test method A," Methyl lodine Penetration Test-30 C at 95% Relative Humidity" as specified in ASTM D3803-1979 (Reference 1) will be used for the second test.
I i
'ODI 1
9701020221 961223 PDR ADOCK 05000333 P
_ ~ ~ -
The results of the sample tested at 95 percent relative humidity will be evaluated to determine the effects of increased humidity on charcoal efficiency. Based on this evaluation, the Authority will consider adopting 95 percent relative humidity for future charcoal adsorber tests 7
performed to satisfy Technical Specification 4.11.A.1.d.
i Standby Gas Treatment System Filter Acceptance Criteria Section 4.7.B.1.c of the FitzPatrick Technical Specifications requires that Standby Gas Treatment System charcoal filter cartridges be removed and adsorption capability demonstrated at least once each year. Future tests to satisfy this requirement will be conducted using an acceptance criteria of less than or equal to 0.175 percent penetration.
Tests will be conducted in accordance with ASTM D3803-1979 (Reference 1).
Updated FSAR Correction Footnote 1 on page 14.8-26 of the FitzPatrick Updated Final Safety Analysis Report (UFSAR),
Section 14.8.3.1, contains an error that will be corrected in the next revision. The footnote states that the FitzPatrick Fuel Reliability Action Plan (FRAP) requires that the control room ventilation system is placed in the isolate mode when a predetermined activity level is
)
exceeded in the RCS. However, this footnote does not accurately reflect the RCS activity i
threshold established in the FRAP. The FSAR states "...when RCS activity exceeds 0.01 Ci/gm I-131 DE." The footnote should read "...when the RCS activity level exceeds 0.01 pCi/cc l-131 which.is equivalent to 0.041 Ci/gm I-131 DE." The reference to dose equivalent
]
(DE) iodine in the current FSAR is incorrect. The other two references to 1-131 DE in the i
footnote are correct and do not need to be changed.
This error was introduced in the 1995 update when the information was incorrectly transcribed from the Authority's safety evaluaticn to the FSAR section. An FSAR change request has been initiated to correct this error.
The next update of the FitzPatrick FSAR will be issued not more than six months after startup from the current refueling outage or July 21,1997, whir.hever is earlier. This schedule complies with the requirements of 10 CFR 50.71(e).
Updated Emergency Action Levels One of FitzPatrick's Emergency Action Levels (EALs)is based upon the maximum RCS activity levels permitted by the Technical Specifications. As part of the proposed changes to the Technical Specifications prepared by the Authority for power uprate, the maximum allowable RCS activity level (Specification 3.6.C.1) was reduced from 3.1 Ci/gm to 0.2 Ci/gm DE l-131.
The Authority has revised the FitzPatrick EALs and the EAL Technical Basis Document to reflect this reduction Specifically, EAL 1.1.1 was changed to establish an action level of 2 pCi/gm DE l-131. This value is still ten times the maximum RCS activity level allowed by Technics. Specifications.
The RCS coolant activity level discussed in EAL 1.2.2 will not be revised since it is based on a j
different value from the NUMARC EAL Task Force. However, a remark in the basis for EAL i
l 1.2.2 which notes a relationship between the old maximum coolant activity and the EAL has been deleted. With the adoption of the new activity level, this relationship is not valid.
Changes to Abnormal Operating Procedures in Reference 1, the Authority committed to implement changes to AOP-28 (Reference 2) prior to startup from the most recent refueling outage, or to complete an analysis supporting the use of 7 SRVs for Fire Areas XV, XVil and XVill. Analyses performed in support of the power uprate project had demonstrated that peak cladding temperatures would remain within acceptable limits assuming 8 SRVs would be available to depressurize the reactor. A new
]
l analysis has been completed which demonstrates that the plant can be safely shutdown with 7 SRVs. As a result, changes to AOP-28 were not necessary.
The Authority also stated that changes to AOP-43 (Reference 3) would be made for Fire Areas Vll, ID and XVI to support the change to 8 SRVs. As a result of this new analysis, these l
changes are no longer necessary. AOP-43 will continue to specify the use of 7 SRVs.
1 Attachment I summarizes the Authority's commitments. If you have any questions regarding this matter, please contact Ms. C. Faison i
Very truly yours,
,f
[
tt William J.' ahill, Jr.
Chief Nucle'ar Officer cc:
Next page I
w..
m
.m
i l
l l
cc:
Regional Administrator
- U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspector U. S. Nuclear Regulatory Commission P.O. Box 136 1
Lycoming, NY 13093 l
l Ms. Karen Cotton, Acting Project Manager Project Directorate I-1 l-Division of Reactor Project 1/11 U.S. Nuclear Regulatory Commission l
Mail Stop 14 B2 l
Washington, DC 20555 l
References:
- 1. ASTM D 3803-79," Standard Test Methods for Radiciodine Testing of Nuclear-Grade Gas-l-
Phase Adsorbents"
- 2. James A. FitzPatrick Nuclear Power Plant, Abnormal Operating Procedure, AOP-28,
" Operation During Plant Fires *"
- 3. ' James A. FitzPatrick Nuclear Power Plant, Abnormal Operating Procedure, AOP-43," Plant Shutdown From Outside The Control Room" l
l i
i
.r Attachment I to JPN-96-055 Summary of Commitments Commitment Number Description Due Date JPN-96-055-01 Conduct annual Control Room Emergency furing the next Ventilation System charcoal test at two scheduled test.
l -
relative humidity level:: 70 percent and 95 percent. Sample tested at 70 percent relative humidity will be used to fulfill the tMting requirements of Technical Spocification 4.11.A.1.d. Test method A in ASTM D3803-1979 will be used.
JPN-96-055-02 Section 4.7.B.1.c of the FitzPatrick Change will be effective Technical Specifications requires that during the next Standby Gas Treatment System charcoal scheduled test filter cartridges be removed and adsorption capability demonstrated at least once each year. Future test to satisfy this requirement l
will be conducted using an acceptance l
l criteria of less than or equal to 0.175 percent penetration. Tests will be l
conducted in accordance with ASTM D38031979.
l l
JPN-96-055-03 Footnote 1 on page 14.8-26 of the Six months after startup
~
l Updated FitzPatrick Final Safety Analysis from the current Report (UFSAR), Sectior 14.8.3.1, refueling outage or July l
contains an error that will be corrected in 21,1997, whichever is l
l the next update.
earlier.
i i
l i
l I
l 1
l I
i i
f l
l
_ _