JPN-99-010, Transmits Revised Exemption Request from Some of Requirements of 10CFR50,App R.Exemption Would Permit Use of CS for Rc Makeup to Achieve Safe Shutdown in Fire Area XI at JAFNPP

Transmits Revised Exemption Request from Some of Requirements of 10CFR50,App R.Exemption Would Permit Use of CS for Rc Makeup to Achieve Safe Shutdown in Fire Area XI at JAFNPP

ML20205G025
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)
References
JPN-99-010, JPN-99-10, NUDOCS 9904070092
Download: ML20205G025 (23)

Text

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, \Wte Plains, New York 10601 914 681.6350 914 287.3309 (Fax)

1. > NewYo.rkPbwer - -w

& Authori Senor Vce President and eser neciee,011,ce, March 31,1999 JPN-99-010 U.S. Nuclear Regulatory Comt..:ssion Attn: Document Control Desk Mail Station PI-137 Washington, DC 20555

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Response to Request for AdditionalInformation and Revised Exemption Request - 10 CFR 50, Appendix R Use of Core Sorav to Achieve Safe Shutdown

REFERENCES:

See below.

Dear Sir:

This letter transmits a revised exemption request from some of the requirements of Appendix R to 10 CFR 50, as detailed in Attachment 2. If approved, the exemption would permit the use of core spray (CS) for reactor coolant makeup to achieve safe shutdown in ,

Fire Area XI at the Authority's James A. FitzPatrick Nuclear Power Plant. This exemption I request supercedes and replaces the request submitted with Reference 2. Attachment 3 provides the information requested by the NRC staff in References 3 and 5.

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Of the six exemptions originally requested by the Authority (Reference 2), the Authority's  !

amended exemption is requesting an exemption for only one area, Fire Area XI-- the South  !

Cable Tunnel. Based on NRC letter dated July 29,1998 (Reference 5), exemptions are not needed for Fire Areas IX (excluding SG-1), X, XV, XVil, and XVill. To address NRC concerns regarding use of low pressure systems in the Standby Gas Treatment System Filter Room (Fire Zone SG-1), a revised Appendix R analysis has been prepared which demonstrates the availability of high-pressure systems in this area. For SG-1, full compliance with Appendix R Section Ill.G.2(a) is demonstrated, eliminating the need for an ,,

exemption. I 0

' }O 9904070092 990331 /

PDR F ADOCK 05000333 PDR g I3 l

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in accordance with the provisions of 10 CFR 50.12(a), the New York Power Authority ,

requests an exemption from the requirements of 10 CFR 50, Appendix R, Sections  !

lil.G.1(a), Ill.L.1(c), Ill.L.1.(e) and Ill L.2(b) as they apply to the James A. FitzPatrick l

Nuclear Power Plant for Fire Area XI, as detailed in Attachment 2. I 1

1 This exemption request adopts the NRC staff's interpretation that the use of low-pressure i systems constitutes alternative shutdown to the extent that the criteria of 10CFR50 Appendix R Sections Ill.G.3 and Ill.L apply as well as the hot shutdown provision of '

ill.G.1(a). The Authority's application for this exemption request does not alter the Authority's previously stated position (Reference 1) regarding the ability of low-pressure systems, including core spray, to achieve safe shutdown at FitzPatrick and FitzPatrick's compliance to Appendix R requirements.

l The attached exemption application will permit the staff to complete its review of the FitzPatrick Appendix R fire protection program and issue a Safety Evaluation Report documenting their approval of the assessment and the continued use cf low-pressure systems. These actions support the resolution of NRC TAC Nos. MA0255, M94518 and M84780.

. Attachment 1 provides introductory material. There are no new commitments made by the Authority in this letter. If you have any questions, please contact Ms. C. D. Faison.

Very truly m0rs, e

im K u el Chief Nuclear Officer  :

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cc: Next Page 2

Attachments:

1. Introduction, Use of Low Pressure Emergency Core Cooling Systems to Achieve Safe Shutdown

2. Revised Request For Exemption From 10 CFR 50, Appendix R Regarding Use Of Low Pressure injection Systems To Achieve Safe Shutdown, Evaluation Pursuant To 10 CFR 4 50.12 Criteria 1

3. Response to NRC Request for Additionalinformation dated December 18,1996 -

Regarding Use of Low Pressure Emergency Core Cooling Systems To Achieve Safe Shutdown cc: Regional Administrator U.S. Nuclear Regulato y Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Mr. J. Williams, Project Manager Project Directorate 1-1 Division of Licensing Project Management U. S. Nuclear Regulatory Commission Mail Stop OWFN 8C2 Washington, DC 20555-0001 i

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Cover Le.tter

References:

1. NYPA letter, W. A. Josiger to USNRC dated July 22,1994 (JPN-94-034) regarding

" Response to Request for AdditionalInformation, FitzPatrick Appendix R Safe Shutdown Capability Assessment."

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2. NYPA letter, W. J. Cahill, Jr. to USNRC, dated January 12,1996 (JPN-96-001) regarding " Request For Exemption From 10 CFR 50, Appendix R Regarding Use Of Low Pressure injection Systems To Achieve Safe Shutdown."

3. NRC letter, K. R. Cotton to W. J. Cahill, Jr. dated December 18,1996 regarding

" Request for AdditionalInformation Regarding Request for Exemption From Section

. Ill.G.1, Ill.L.1 and Ill.L.2 of Appendix R to 10 CFR Part 50 (TAC No. M94518)."

4. USNRC/NYPA meeting handout, October 6,1997, " Low-Pressure ECCS as Redundant Safe Shutdown at the James A. FitzPatrick Nuclear Power Plant."

5. NRC letter, J. F. Williams to J. Knubel, dated July 29,1998, regarding " Evaluation of the Historical Licensing Basis for Requests for Exemption from the Requirements of Appendix R to 10 CFR 50 (TAC No. MA0255)." ,

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l Attrchment 1 to JPN-99-010

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l Introduction  !

Use of Low Pressure Emergency Core Cooling Systems To Achieve Safe Shutdown {

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1 James A. FitzPatrick Nuclear Power Plant New York Power Authority Docket No. 50 333 1

l l l Attzchment 1 ta JPN-99-010 Introduction - Use of Lew Pressure Emeraency Core Coolina Systems l to Achieve Safe Shutdown INTRODUCTION i The Authority is requesting an exemption from some of the requirements of 10 CFR 50, ,

Appendix R as they apply to the James A. FitzPatrick Nuclear Power Plant as described l below, in accordance with the provisions of 10CFR50.12(a), the New York Power Authority requests exemption to the requirements of 10CFR50 Appendix R, Sections Ill.G.1(a) and Ill.L.1(c) to the extent that the hot shutdown maintenance provisions of these sections may not be satisfied, Section Ill.L.1(e) to the extent that the reactor coolant process variables may not be maintained within the limits predicted for a loss of normal a.c. power and Section Ill.2.b to the extent that the reactor coolant makeup function may not maintain the reactor coolant level above the top of the core during a fire in the South Cable Tunnel.

This exemption request supercedes and replaces the exemption request submitted with Reference 11. Based on the NRC staff's conclusion documentation Reference 14, exemptions are not needed for Fire Areas IX (excluding SG 1), X, XV, XVll, and XVill. To address NRC concerns regarding use of low pressure systems in the Standby Gas Treatment System Filter Room (Fire Zone SG-1), a revised Appendix R analysis has been prepared which demonstrates the availability of high-pressure systems in this area.

In the revised request, the number of exemptions has been reduced from six to one. Based on the staff's July 29,1998 evaluation of the historicallicensing basis for FitzPatrick (Reference 14), four of the exemptions requested in January 1996 have been determined not to be required. A revised Appendix R analysis demonstrates that high-pressure systems will be available in Fire Zone SG-1, the Standby Gas Treatment System (SBGTS)

Filter Room. Consequently, an exemption for this area is unnecessary. Of the six original exemptions, only Fire Area XI-- the South Cable Tunnel, remains. For this fire area, exemption from the certain performance requirements of Sections Ill.G.1(a), Ill.L.1, Ill.L.2 and Ill.G 1 of Appendix R to 10 CFR 50 is requested as detailed in Attachment 2. l The format and content of the exemption is based on the criteria of 10 CFR 50.12 for exemptions.

CHANGES FROM PREVIOUS EXEMPTION REQUEST A summary of the changes are outlined below.

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AttichmInt 1 to JPN-99-010 Introduction - Use of Low Pressure Emeraency Core Coolina Systems to Achieve Safe Shutdown I Fire Area / Zone IX l A revised Appendix R assessment will creuit the existing separation of the SBGTS filter room from the balance of Fire Area IX and designate it a separate Fire Zone SG-1. Since this new area does not contain cables and circuitry critical to the operation of either the Reactor Core Isolation Cooling (RCIC) or High Pressure Coolant injection (HPCI) systems, the revised assessment takes credit for these high-pressure systems for reactor coolant '

makeup in the event of a fire in this area.

This arrangement is consistent with the original 1982 Appendix R assessment for FitzPatrick (Reference 1). Consequently, an exemption for this area is unnecessary. j Fire Area XI, South Cable Tunnel Of the six exemptions originally requested by the Authority, the Authority's amended exemption is requesting an exemption for only one area, Fire Area XI-- the South Cable Tunnel.

For this fire area, exemption from the certain performance r3quirements of Sections Ill.G.1(a), Ill.L.1(c), Ill.L.1(e) and Ill.L.2.b of Appendix R to 10 CFR 50 is requested as detailed in Attachment 2.

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Att chm:nt 1 to JPN-99-010 Introduction - Use of Low Pressure Emeroency Core Coolina Systems to Achieve Safe Shutdown ATTACHMENT 1 REFERENCES

1. NYPA letter, J. P. Bayne to H. R. Denton dated July 13,1982 (JPN-82-061) submitted "A Reassessment of the James A. FitzPatrick Nucleer Power Plant for Conformance to the Requirements of Appendix R to 10 CFR 50."

2. NRC letter, Domenic B. Vassallo to Corbin A. McNeill, dated January 11,1985, regarding " Exemptions Requests - 10 CFR 50.48 Fire Protection and Appendix R to 10 CFR Part 50"

3. NRC Generic Letter 86-10 " Implementation of Fire Protection Requirements," dated April 24, 1986

4. NRC letter, Robert M. Bernero to John C. Brons, dated September 15,1986, regarding

" Exemption From Appendix R to 10 CFR 50 Concerning Core Uncovery During Alternate Safe Shutdown"

5. NYPA letter JFN 92-043, Ralph E. Beedle to NRC, dated July 31,1992, regarding

" Revision to Exemption From 10 CFR 50, Appendix R"

6. NRC letter, Robert A. Capra to Ralph E. Beedle, dated September 10,1992, regarding

" Issuance of Exemptions From Requirements of 10 CFR Part 50, Appendix R, for the James A. FitzPatrick Nuclear Power Plant"

7. NYPA letter, R. E. Beedle to USNRC dated October 26,1992 (JPN-92-064) regar0 g

" Fire Protection Program,1992 Safe Shutdown Capability Assessment."

8. New York Power Authority, Safe Shutdown Capability Reassessment 10 CFR 50 Appendix R, James A. FitzPatrick Nuclear Power Plant, November 1992

9. NRC letter, J. E. Menning to W. A.' Josiger dated May 18,1994 regarding " Request for AdditionalInformation - Appendix R Reassessment of Safe Shutdown Capability for the James A. FitzPatrick Nuclear Power Plant (TAC No. M84780)."

10.NRC letter, C. E. Carpenter, Jr. to W. J. Cahill, Jr., dated September 5,1995, regarding Safety Evaluation of Safe Shutdown Capability Reassessment for James A. FitzPatrick Nuclear Power Plant" (TAC No. M84780).

11.NYPA letter, W. J. Cahill, Jr. to USNRC, dated January 12,1996 (JPN-96-001) regarding request for exemption from 10 CFR 50, Appendix R regarding use of low pressure injection systems to achieve safe shutdown.

12.NRC letter. K. R. Cotton to W. J. Cahill, Jr. dated December 18,1996 regarding

" Request for AdditionalInformation Regarding Request for Exemption from Section Ill.G.1, Ill.L.1 and Ill.L.2 of Appendix R to 10 CFR 50 (TAC No. M94518)."

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AttIchment 1 to JPN-99-010 Introduction - Use of Low Pressure Emeraency Core Coolina Systems Lg Achieve Safe Shutdown 13.USNRC/NYPA meeting handout, October 6,1997, " Low Pressure ECCS as Redundant Safe Shutdown at the James A. FitzPatrick Nuclear Power Plant."

14.NRC letter, Joseph F. Williams (USNRC) to James Knubel (NYPA) dated July 29,1998 regarding evaluation of the historicallicensing basis for requests for exemption from the requirements of Appendix R to 10 CFR 50 (TAC No. MA0255).

15.NYPA letter, J. Knubel to USNRC dated February 26,1999 (JPN-99-006) regarding response to NRC request for additional information, amended exemption request -10 CFR 50, Appendix R, use of low-pressure injection Systems to Achieve Safe Shutdown.

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AttIchment 2 ta JPN-99-010 e

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l Request For Exemption from Selected Performance Criteria of 10 CFR 50, Appendix R l Regarding Use of Low Pressure Emergency Core Cooling Systems .

To Achieve Safe Shutdown Ma,ch 31,1999 James A. FitzPatrick Nuclear Power Plant New York Power Authority Docket No. 50-333

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Attichm:nt 2 to JPN-99-010

Reauest For Exemption from Selected Performance Criteria of 10 CFR 50, Aooendix R Reaerdina Use of Low Pressure Emeraency Core Coolina Systems To Achieve Safe Shutdown I

EVALUATION PURSUANT TO 10 CFR 50.12 CRITERIA l

EXEMPTION REQUESTED l In accordance with tiie provisions of 10CFR50.12(a), the New York Power Authority i

requests exemption to the requirements of 10CFR50 Appendix R, Sections Ill.G.1(a) and lil.L.1(c) to the extent that the hot shutdown maintenance provisions of these sect.sns may not be satisfied, Section Ill.L.1(e) to the extent that the reactor coolant process variables j may not be maintained within the limits predicted for a loss of normal a.c. power and '

Section Ill.2.b to the extent that the reactor coolant makeup function may not maintain the ,

reactor coolant les'-l above the top of the core during a fire in the South Cable Tunnel. '

The safe shutdow, atrategy for Fire Area XI, (the South Cable Tunnel) utilizes the core spray system in conjunction with the manual operation of the safety relief valves (SRVs) to l depressurize the reactor, to provide reactor coolant makeup.

PHYSICAL ARRANGEMENT AND FIRE PROTECTION FEATURES Fire Area Boundaries Fire Area XI (also referred to as Fire 2)ne CT-3 or the South Cable Tunnel) is a cable tunnel through which the majority of Division B cables routed from the control room complex to the reactor building are routed.

Fire Area XI is separated from the adjoining plant areas by three hour-rated fire barriers.

The north wall and portions of the west wall separate Fire Area XI from the North Cable Tunnel (Fire Area 1D). Other portions of the west wall ::eparate Fire Area XI from the Steam Tunnel (Fire Area IE). The floor and ceiling of Fire Area XI separate it from porte.w of the Administrat:on Buildirm (Fire Area 1 A). The east wall separates Fire Area XI from the Relay Room (Fire Area Vil). Exposed structural steelin these barriers has been protected with tireproof material to pruvent failure of the steelin the event of a fire in this area.

! Fixed Combustible and lanition Sources The primary combustibles in this area are cables. This area has no significant insitu ignition sources other than two wall mounted Dry Type Transformers, the South Cable Tunnel Unit l No%r, a Security System Radio Transmitter and an Eme*gency Lighting Unit and ".e l c nes themselves.

Fire Detection Capabilities Fire Area XIis provided with full area ionization smoke detectors. In addition, Fire Area XI is provided with rate compensated heat detectors, which also actuate an automatic full area CO2 system.

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t Att:chment 2 t2 JPN-99-010 Reauest For Exemotion from Selected Performance Criteria of 10 CFR 50, Aooendix R l Reaardina Use of Low Pressure Emeraency Core Coolina Systems To Achieve Safe i

Shutdown Fire Suporession Caoabilities Fire Area XI is provided with a full area total flooding CO2 system. This system is designed to attain a 50% CO2concentration to maximia its effectiveness for suppressing deep-  !

seated cable fires.

l A hose station, located in the adjacent area (the Relay Room), is capable of providing an

! j effective hose stream throughout Fire Area XI. Portable fire extinguishers are also available.

l Safe Shutdown Capabilities '

l A significant portion of the Division B safe shutdown systems for the facility may be adversely affected by a fire in this area as the South Cable Tunnel is the primary routing path between the control room complex and the reactor building. Refer to the FitzPatrick Appendix R Safe Shutdown An.4' sin (Reference 3) for additionalinformation about the safe l shutdov n systems in the F sa/ Zone XI/CT-3.

Division A high-pressure restor coolant system makeup from the Reactor Core Isolation l

Coo ~ ling (RCIC) system is not ensured for a fire in this area. The Division B inboard l

! containment isolation valvc for steam admission to the RCIC turbine (13 MOV-15) has cables associated with it in this area, which can cause the spurious closure of this valve.

Potential circuit damage as well as potential unavailability of motive power to re-open the valve can prevent remote operation of this valve, if it should close. Consequently, remote operation can not be credited without physical modifications. This valve is located within the primary containment and manual action to re-open it in a timely fashion would be difficult and would expose personnel to undue risk. For the purposes of Appendix R l analyses, valve 13 MOV-15 was assumed to failin the closed position, thereby disabling RCIC.

1 Consequently. eactor coolant makeup is ensured in this area by the use of the Division A core spray system in conjunction with manual operation of the safety relief valves to depressurize the reactor from the Control Room.

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, AttschmInt 2 to JPN-99-010  !

Reauest For Exemotion from Selected Performance Criteria of 10 CFR 50, Anoendix R ,

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. AttichmInt 2 to JPN-99-010 Reauest For Exemotion from Selected Performance Criteria of 10 CFR 50, Anoendix R Reasrdina Use of Low Pressure Emeraency Core Coolina Systems To Achieve Safe Shutdown JUSTIFICATION FOR EXEMPTION i The requested exemption satisfier, the 10 CFR 50.12 criteria as stated below:

The requested exemption is authorized by law 10 CFR 50.12(a) authorizes the Nuclear Regulatory Commission to grant this exemption.

The requested exemption does not present an undue risk to the public health ar.J Safety Accendix R Sections Ill.G.1(a) and Ill.L.1(c)

Appendix R Sections Ill.G.1(a) and Ill.L.1(c) require that one train of systems necessary to achieve and maintain hot shutdown remain free of fire damage. With the core spray  ;

system, in conjunction with the SRVs, used to satisfy reactor coolant makeup needs, it  !

may not be possible to maintain the reactor in hot shutdown in the period during and following the injection phase under some plant condition.

The maintenance of hot shutdown, as stipulated in Sections Ill.G.1(a) and Ill.L.1(c) is not necessary to ensure safe shutdown is achieved and maintained when the core spray system, in conjunction with manual operation of the safety relief valves (SRVs) is ut:!! zed i for reactor coolant makeup. This is because even if the reactor coolant temperatures should l drop below the point the reactor could be considered in cold shutdown, the core spray system is still capable of providing reactor coolant makeup. These conditions are well within the range for which cora spray is designed to function. Under most circumstances for which core spray is utilized for reactor coolant makeup, the reactor will either remain in hot shutdown during and after the injection phase or will return to hot shutdown after the sensible cooling provided by the relatively coolinjection fluid is overcome by decay heat.

This is because the method of decay heat removal from the vessel is primarily boiling, which ensures the bulk temperature will exceed 212 degrees F for all but the lowest decay heat levels.

Further, ensuring the availability of systems capable of maintainirm hot standby conditions until a gradual reactor coolant system depressurization could be iiiitiated and the reactor deprensurized to the point core spray could be effective provides only limited safety benefit. This H because the core spray system, in conjunction with the SRVs, as intended to be used during a fire, provides extremely effective core cooling. The peak clad temperatures during the associated transient stay below the normal operating value of 596 degrees F. This is particularly true for the South Cable Tunnelin that provisions to operate all eleven SRVs from the control room have been ensured. Transient analysis JAF-RPT-

'The James A FitzPatrick Technical Specifications define hot standby as the coolant temperature above 212 degrees F with the mode switch in start-up/ hot standby and reactor pressure less than 1040 psig.

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. AttIchm nt 2 to JPN-99-010 Recuest For Exemotion from Selected Pt irmance Criteria of 10 CFR 50, Anoendix R Reaardina Use of Low Pressure Emeraens Qore Coolina Systems To Achieve Safe Shutdow MISC-02599 (Raference 4) demonstrates as few as seven valves are adequate for this purpose.

Consequently, although Appendix R Sections lli.G.1(a) and Ill.L.1(c) hot shutdown provision may not be satisfied, use of core spray in conjunction with the SRVs for reactor coolant make up, will not unduly risk the health and safety of the public.

Aooendix R - Section Ill L.1(e)

In part,10CFR50 Appendix R, Section Ill.1(e) requires that the reactor coolant system process variables be maintained within those predicted for a loss of normal a.c. power.

When the core spray system, in conjunction witl the SRVs, are utilized to satisfy reactor coolant makeup requirements, the reactor coolant system pressure and reactor coolant level, can exceed the limits anticipated for a loss of normal a.c power. Consequently, this specific performance requirement may not be met. Although, these specific criteria are not met, the core spray system, in conjunction with the SRVs is fully capable of achieving and maintaining stable safe shutdown, without challenging the reactor coolant system and fuel beyond the limits for which they are designed, as described in the previous section.

Consequently an undue risk to the health public and safety of the public will not be created.

Accendix R - Section Ill L.2.b Appendix R Section Ill.L.2.b specifically requires, the reactor level be maintained above the top of the core for BWRs. The proposed shutdown strategy does not necessarily ensure that this requirement is met. l Although, this specific criterion may not be met, the core spray system, in conjunction with the SRVs is fully capable of achieving and maintaining stable safe shutdown, without challenging the reactor coolant system and fuel beyond the limits for which they are designed, as described above. Consequently an undue risk to the health public and safety of the oublic will not be created.

Similar Exemotions The NRC issued exemptions dated September 15,1986 (Reference 1) and September 10, 1992 (Reference 2) which permitted the reactor coolant level to drop below the top of the core during the use of safe shutdown procedures following control room evacuation. The conclusion that the exemption would nut pose an undue risk to the public hea!th and safety was in part, based on an analysis which demonstrated that the short-term core uncovering associated with the selected shutdown strategy (which relied on either low-pressure core injection or core spray) would not challenge fuel-cladding integrity.

The core uncovery associated with tha use of core spi sy in the South Cable Tunnelis less severe, with resulting lower peak clad temperatures. as compared to the above referenced exemptions. On a similar basis it should also be concluded, for the subject request, the use 6

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. Attichmint 2 to JPN-99-010 I Reouest For Exemotion from Selected Performance Criteria of 10 CFR 50, Aooendix R Reaardina Use of Low Pressure Emeraencv Core Coolina Systems To Achieve Safe i Shutdown I of core spray in the South Cable Tunnel would not unduly risk the public health and safety, as the conditions presented in the NRC approved exemption are bounding, i

The requested exemption is consistent with the common defense and security The common defense and security are not affected by this exemption request.

SDeCI8l circumstances are Dresent as defined in 10 CFR 50.12(a)(2)  :

1 10 CFR 50.12(a)(2) states, in part:

"The Commission willnot consider granting an exemption unless special circumstances are present. Specialcircumstances are prcsent whenever... (ii)

Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is it necessary to achieve the underlying purpose of the rule; or (iii) Comoliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated. "

Underlying purpose of the rule Maintenance of Hot Shutdown - Ill.G.1(a) and Ill.L.1(c)

Compliance with the performance criteria of Section Ill.G.1(a) and Ill.L.1(c) is not necesrecy to achieve the underlying purpose of the rule since safe shutdown conditions can be I maintained with the use of core spray and SRVs. I Reactor Coolant System Pressure - Ill.L.1(e)

The inability to maintain the reactor coolant system pressure with the range predicted for a loss of normal a.c. power is not essential to satisfying the underlying purpose of the rule in that safe shutdown conditions can be achieved and maintained with the proposed safe shutdown strategy. The plant is specifically designed to withstand the associated pressure transient.

Reactor Coolant Svstem level - lli.L.2.b The inability to maintain the reactor vessellevel above the top of the core does not defeat the underlying purpose of the rule in that only short term core uncovery results. This limits the peak icel clad temperature to within normal operating temperature. Consequently, no i fuel damage is expected.

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Attichm;:nt 2 to JPN-99-010 Reauest For Exemption from Selected Performance Criteria of 10 CFR 50, Accendix R Reaardina Use of Low Pressure Emeraency Core Coolina Systems To Achieve Safe Shutdown l CONCLUSION This exempt!on request is warranted under the provisions of 10 CFR 50.12, in that it is authorized by law, does not present an undue risk to the public health and safety, is consistent with the common defense and security.

Special circumstances are present considering the inability to: (1] maintain reactor coolant system process variables (e.g. reactor coolant level and pressure) within the ranges predicted for a loss of normal a.c. power (compliance with Section Ill.L.1(e)); (21 maintain reactor coolant level above the top of the core (compliance with Section Ill.L.2.b); and (3]

achieve and maintain hot shutdown conditions (compliance with Sections Ill.G.1(a) and Ill.L.1(c)) does not defeat the underlying purpose of the rule. Safe shutdown conditions can be achieved and maintained with the proposed shutdown strategy with no fuel damage expected.

This exemption request is consistent with the ultimate objective of Appendix R which is safe shutdown. There is no need to, or safety benefit associated with, meeting the performance criteria of Ill.G.1(a), Ill.L.1(c), Ill.L.1(e) or Ill.L.2.b since use of the core spray has been shown to be a safe, effective means of achieving safe shutdown.

The information contained in this exemption application will permit the staff to complete its review of the FitzPatrick Appendix R fire protection program and issue a Safety Evaluation Report documenting their approval of the assessment and the continued use of low-pressure systems.

Existing Appendix R analyses, procedures and operator training provide an equivalent level of protection and assure that the plant could be safely shutdown in the event of a fire in the South Cable Tunnel, Fire Area / Zone >'l/CT-3 utilizing the core spray system in conjunction with the SRVs.

The Authority has reviewed Appendix R exemptions issued by the NRC for FitzPatrick. The bases of these exemptions are not affected by this exemption request and will remain valid if the exemption is granted.

These actions support the resolution of NRC TAC Nos. MA0255, M94518 and M84780.

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. AttIchm:nt 2 to JPN-99-010 Reauest For Exemotion from Selected Performance Criteria of 10 CFR 50, Accendix R Reaardina Use of Low Pressure Emeraency Core Coolina Systems To Achieve Safe Shutdown ATTACHMENT 2 REFERENCES

1. NRC letter, Robert M. Bernero to John C. Brons, dated September 15,1986, regarding

" Exemption From Appendix R to 10 CFR 50 Concerning Core Uncovery During Alternate Safe Shutdown"

2. NRC letter, Robert A. Capra to Ralph E. Beedic, dated September 10,1992, regarding

" Issuance of Exemptions From Requirements of 10 CFR Part 50, Appendix R, for the James A. Fitz?atrick Nuclear Power Plant"

3. NYPA letter, R. E. Beedle to USNRC dated October 23,1992 (JPN-92-064) submits Safe Shuttlown Capability Reassessment 10 CFR 50 Appendix R, James A. FitzPatrick Nuclear Power Plant, November 1992

4. New York Power Authority report JAF-RPT-MISC-02599, "JAF Peak Clad Temperature for an Appendix R Event."

5. Appendix A to Facility O,nerating License No. DPR-59, Technical Specifications and Bases for James A. Fit #3 trick Nuclear Power Plant, Power Authority of the State of New York, Docket No. 50-333, as amended.

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. Attschment 3 to JPN-99-010 l

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Response to NRC Request for Additional Information dated 4 December 18,1996  !

Regarding Use of Low Pressure Emergency Core Cooling Systems  !

To Achieve Safe Shutdown I

I March 31,1999 Jamos A. FitzPatrick Nuclear Power Plant i New York Power Authority Docket No. 50-333

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. Attachm:nt 3 to JPM-99-010 l Response to NRC Reauest for Additionalinformation Dated December 18,1996 Reaardina Reauest'for Exemption From Section Ill.G.1, Ill.L 1 and ll!.L.2 of Aooendix R to 10 CFR 50  ;

(TAC No. M94518)

Introduction This attachment responds to three questions asked by the NRC staff in letter dated December 18,1996 (Reference 2) and July 29,1998 (Reference 3) regarding the Authority's January 12,1996 Appendix R exemption request (Reference 1).

Question 1 The proposed LPIS approach does not appear to satisfy the " hot shutdown" performance criterion of Section Ill.G.1, Ill.G.2, and Ill.G.3 of Appendix R to 10 CFR Part 50. Generic Letter 86-10 provides further clarification and staff positions with regard to defining

" alternative" and " redundant" shutdown capabilities, in light of these requirements, it appears the proposed approach is providing an alternative shutdown capability for the l- identified fire areas. Please explain why the use of LPIS is not identified by PASNY as

, providing an alternative shutdown capability for Fire Areas IX, X, XI, XV, XVil, and XVill.

l Response 1 The Authority is working with the BWR Owners' Group and General Electric on a position paper, wW5 will respond to this ques, tion. The Authority expects that this paper will be l applicable to FitzPatrick. The position paper will address the use of safety relief valves and l low pressure systems (including core spray) as redundant safe shutdown paths. The paper will examine the acceptability of using low-pressure systems from a regulatory, a safety and risk significance perspective.

The Authority will continue to work with the BWROG to resolve the NRC's concerns regarding this issue.

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. Attrchmsnt 3 to JPN-95-010 Resoonse to NRC Reauest for AdditionalInformation Dated December 18,1996 Reaardina Reauest'for Exemotion From Section Ill G.1, Ill.L.1 and lil.L.2 of Aooendix R to 10 CFR 50 (TAC No. M94518)

QUESTIOri 2 Fire Area 9 IX, X, XI, XV, XVil, and XVill are described in the PASNY revised analysis (" Safe Shutdovin Capability Reassessment 10 CFR Part 50 Appendix R, James A. FitzPatrick Nuclear Power Plant," dated November 1992) as satisfying the separation and protection requirements of Section Ill.G of Appendix R. However, as described above, LPIS appears to be providing an alternative shutdown capability for these areas. Therefore, please explain why Fire Areas IX, X, XI, XV, XVil, and XVill have not been designated as alternative shutdown fire areas.

RESPONSE 2 Fire Areas IX, X, XV, XVil and XVill in Reference 3, the NRC staff concluded that exemptions were not required for five of the six areas mentioned (Fire Areas IX (excluding SG-1), X, XV, XVil and XVlll).

Fire Zone SG-1 For SG-1, the Authority has revised the Appendix R analysis to credit the existing separation between SG-1 and the balance of Fire Area IX, and designate it a separate fire area. This revised analysis h6s demonstrated the availability of both HPCI and RCIC. l

. Consequently, applying the staff's definition of alternative shutdown, SG-1 could be considered a redundant shutdown area.

Fire Area XI I The Authority has submitted an exemption with this attachment for the one remaining fire area (Fire Area XI) which requests exemption from certain performance requirements of 10 CFR 50, Appendix R, Sections Ill.G.1, Ill L.1 and lli.L.2. Refer to Attachment 1 for additionalinformation about Fire Area XI.

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. Attichm:nt 3 to JPN-99-010 Resoonse to NRC lieauest for AdditionalInformation Dated December 18,1996 Reaardina Reauest*for Exemotion From Section Ill.G.1 lil.L.1 and Ill.L.2 of Accendix R to 10 CFFi 50 (TAC No. M94518)

OUESTION 3 Section Ill.G.3 of Appendix R states that for alternative shutdown capabilities, " fire detection and a fixed fire suppression system shall be installed in the area, room or zone under consideration." For Fire Areas IX, X, XI, XV, XVil, and XVill provide justification why this requirement is not met and an exemption for this requirement should be granted (i.e.

equivalent safety exists).

I RESPONSE 3 l

Fire Areas IX, X, XV XVil and XVill In Reference 3, the NRC staff concluded that exemptions were not required for five of the six areas mentioned (Fire Areas / Zones IX (excluding SG-1), X, XV, XVil and XVill).

Fire Zone SG-1 l l

l For SG-1, the Authority has revised the Appendix R analysis to credit the existing separation between SG-1 and the balance of Fire Area IV, and designate it a separate fire area. This revised analysis has demonstrated the availability of both HPCI and RCIC.

Consequently, applying the staff's definition of alternative shutdown, SG-1 could be considered a redundant shutdown area. Consequently, the provisions of Appendix R Section ill.G.3 due not apply. Further, as circuitry critical to tFe operation of both HPCI and RCIC are independent of SG-1, the provis;ons of Appendix R, Section lil.G.2.a apply, I which do not require full area suppression and detection.

Fire Area XI I

Detection and suppression systems are currently installed in Fire Area XI. Refer to 1 Attachment 1 for additionalinformation regarding Fire Area XI.

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, AttrchmInt 3 to JPN 99-010 Response to NRC Reauest for AdditicaalInformation Dated December 18.1996 Recardina Reauest'for Exemotion From Section Ill.G.1, Ill.L.1 and Ill.L.2 of Accendix R to 10 CFR 50 (TAC No M94518)

ATTACHMENT 3 REFERENCES

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1. NYPA letter, W. J. Cahill, Jr. to USNRC, dated January 12,1996 (JPN-96-001) regarding " Request For Exemption From 10 CFR 50, Appendix R Regarding Use Of Low Pressure injection Systems To Achieve Safe Shutdown."

2. NRC letter, K. R. Cotton to W. J. Cahill, Jr. dated December 18,1996 regarding

" Request for AdditionalInformation Regarding Request for Exemption From Section Ill.G.1, ill.L.1 and Ill.L.2 of Appendix R to 10 CFR Part 30 (TAC No M94518)."

3. NRC letter, J. F. Williams to J. Knubel, dated July 29,1998, regarding " Evaluation of the Historical Licensing Basis for Requests for Exemption from the Requirements of Appendix R to 10 CFR 50 (TAC No. MA0255)."

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