JPN-99-008, Forwards Application for Amend to License DPR-59,converting CTS to Be Consistent with Improved Std TS in NUREG-1433, Rev 1.Synopsis of LAR for Conversion to Its,Pending Lars, List of Subsections,Scope of Changes & Commitments,Encl

Forwards Application for Amend to License DPR-59,converting CTS to Be Consistent with Improved Std TS in NUREG-1433, Rev 1.Synopsis of LAR for Conversion to Its,Pending Lars, List of Subsections,Scope of Changes & Commitments,Encl

ML20205D820
Person / Time
Site:	FitzPatrick
Issue date:	03/31/1999
From:	James Knubel POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205D824	List: JPN-99-008, Forwards Application for Amend to License DPR-59,converting CTS to Be Consistent with Improved Std TS in NUREG-1433, Rev 1.Synopsis of LAR for Conversion to Its,Pending Lars, List of Subsections,Scope of Changes & Commitments,Encl ML20205D827
References
RTR-NUREG-1433 JPN-99-008, JPN-99-8, NUDOCS 9904050009
Download: ML20205D820 (5)

Text

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123 Ma,n Street i Yhwta Plains New York 10601 914 681.6840 914 2873309 (FAX)

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March 31,1999 JPN-99--008 U. S. Nuclear Regulatory Commission Attn: Document Con'.rol Desk Washington, D C 20555-0001

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59

Proposed Technical Specification Change (License Amendment)

Conversion to improved Standard Technical Specifications

References:

1. NUREG-1433, " Standard Technical Specifications-General Electric Plants BWR/4" Revision 1, dated April 1995.

2. NEl 96-06, " improved Technical Specifications Conversion Guidance,"

dated August 1996.

3. JPN-98-005, NYPA letter to NRC, " Revision to Proposed Technical Specification Change (JPTS-95-004, inserv,ce Leak and Hydrostatic Testing Operation)," dated February 6,1998.

4. JPN-98-055, NYPA letter to NRC, " Withdrawal of Proposed Technical Specification Amendment (JPTS-95-004) Regarding inservice Leak and Hydrostatic Testing Operation (TAC No. MA1135).

Dear Sir:

The New York Power Authority hereby proposes to amend the James A. FitzPatrick Nuclear r Power Plant Operating License, Appendices A and B, Techne,al Specifications (TS) to convert \,

the James A. FitzPatrick current Technical Specifications (CTS) to be consistent with the improved Standard Technical Specifications (ISTS) (Reference 1). This application is submitted pursuant to 10 CFR 50.90.

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The proposed license amendment request to convert the FitzPatrick CTS to the FitzPatrirk O

= lmproved Technical Specifications (ITS) is enclosed with this letter. The proposed license amendment request was prepared consistent with guidance provided in Nuclear Energy a Institute (NEI) NEl 96-06, " improved Technical SpeciGeations Conversion Guidance," dated /

' August 1996 (Reference 2). fkQ F

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The submittal for the conversion of the FitzPatrick CTS to the FitzPatrick ITS consists of five (5) sections collected into 19 volumes. The 5 sections of the conversion submittal are as follows:

1. Application of NRC Selection Criteria including the CTS to ITS Disposition and Relocation Matrix (Split Report);

ll. FitzPatrick ITS Specifications and ITS Bases; lll. FitzPatrick CTS Master Markup; IV. FitzPatrick Conversion Packages and Relocated Requirements -

Descriptions and Justifications for the conversion of FitzPatrick CTS to FitzPatrick ITS and, Descriptions and Justifications for the relocation of selected FitzPatrick CTS requirements and details; and, V. Evaluations supporting a finding of No Significant Hazards Considerations (NSHC) as required by 10 CFR 50.91(a) for proposed changes classified as Administrative (A), More Restrictive (M), Removed Detail (LA and LB) or Relocated (R) (Note that NSHCs for changes classified as Less Restrictive (L) are included in Section IV);

Attachment 1 of this letter, " Synopsis of the License Amendment Request For Conversion to improved Technical Specifications (ITS)," provides a detailed description of the organization and contents of each Section, and of each volume of the submittal.

To facilitate your review,Section IV, FitzPatrick Conversion Packages and Relocated Requirements, are divided into 141 subsections. Each subsection is designed to allow it to be reviewed independently. Attachment 2 of this letter is a list of these subsections and a Table of Contents of this submittal.

Attachment 3, "Pending License Amendment Requests," provides a listing of all currently docketed license amendment requests. These amendment requests are incorporated into the conversion packages. Each conversion package clearly identifies where pending license amendment requests are used as the starting point for the conversion to ITS. During the period of NRC review of the FitzPatrick ITS, supplemental submittals incorporating pending changes to j the CTS will be made where necessary. These submittals will be scheduled with the NRC staff to ensure that the ITS and CTS review processes are efficiently coordinated.

A license amendment request concerning inservice Leak and Hydrostatic Testing (Reference 3) has also been incorporated into this conversion package. The proposed amendment was subsequently withdrawn via Reference 4. However, this occurred too recently for it to also be deleted from the conversion package. The Authority will submit a supplement to the ITS conversion submittal to reflect the withdrawal of this proposed amendment by June 1,1999.

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Improved Standard Technical Specification (ISTS) Change Travelers and their approval status are identified in Attachment 4, ~ ISTS Change Traveler status is provided for each Traveler incorporated into the JAFNPP ITS.

The Authority has endeavored to limit the Technical Specification changes to those required to establish conformance with the ISTS. However, in several cases, changes were made to the current licensing basis which are beyond the scope of the conversion to ISTS. The FitzPatrick Conversion Packages provide sufficient detail to demonstrate the need for these changes and to support timely review and approval. These beyond scope changes are listed in Attachment 5.

The FitzPatrick CTS numerical values are nominal or analytical values. The numerical values in the Improved Technical Specifications are Allowable Values. Where practical, the Authority took the approach of retaining the CTS numerical value as the ITS Allowable Value. This was done to facilitate training of licensed operators and other personnel, and to reduce the number

- of procedure and document changes needed for implementation. Nearly every Allowable Value required a calculation to either demonstrate the acceptability of the current analytical value, or to establish a new one that would allow the CTS value to be retained as the Allowable Value in .

the ITS.

Calculations and verification have been completed for about 24 of the approximately 101 ITS Allowable Values (AVs). Calculations for approximately 70 AVs are complete and remain to be verified. No changes to the 70 affected AVs are anticipated during verification of these calculations. An additional seven (7) AVs may require revision following completion of the calculations. All seven of these values are shown in brackets in the submittal.' One of these, the scram due to main steam isolation valve closure, requires additional transient and accident analysis and verification of the analytical work. The Authority will provide the NRC with a date by which the necessary work will be completed during a meeting to discuss this submittal. The Authority will notify the NRC promptly of any changes to this submittal resulting from this effort.

Implementation of the FitzPatrick ITS will require the performance of a number of new or revised surveillance requirements. The Authority intends to treat these requirements as being

" met" at the time of implementation, with the first performance of these new or revised surveillance requirements scheduled to be completed within the required frequency from the date of implementation.

The Authority intends to discuss the date for implementation of this proposed license amendment request for FitzPatrick at an upcoming meeting with the NRC. This date will be based on the timing of implementation with respect to the planned refueling outage and the scheduling of licensed operator training.

There are two new commitraents contained in this letter. They are summarized in Attachment 6.

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A meeting has been scheduled for April 14,1999 to discuss the review schedule and contents of this license amendment request. Should you have any questions or require additional information, please contact the FitzPatrick ITS Project Manager, Mr. J. A. Gray, Jr. at (914) 681-6289.

Yours truly,

/J. Chief Knubel Senior Vice President and Nuclear Officer JK: JAG:sd Attachments cc: Next Page 4

CC:

. Regional Administrator U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

-Resident inspector's Office James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission P.O. Box 134

. Lycoming, NY 13093 Mr. F. William Valentino, President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12223-6399 Mr. J. Williams, Project Manager Project Directorate 1-1 Division of Licensing Project Management U. S. Nuclear Regulatory Commission Mail Stop 14B2 Washington, DC 20555 William D. Beckner, Chief Technical Specifications Branch U. S. Nuclear Regulatory Commission Mail Stop 13H15 Washington, DC 20555