ML19354E038
| ML19354E038 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 01/16/1990 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML19354E033 | List: |
| References | |
| NUDOCS 9001250278 | |
| Download: ML19354E038 (19) | |
Text
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ATT.'CHMENT I PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING C_ONTAINMENT LEAK RATE TEST REQUIREMENTS (JPTS 84-012) i NewYork Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59
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4 JAFNPP
~
3.7 (cont'd) 4.7 (cont'd)
(2)
During testing which adds heat to the suppression pool, the water temperature shall not exceed 10 F above the normal power operation limit specified in (1) above. In cunisection with such testing, the pool temperature must be reduced to below the rtW powe operation limit specified in (1) above wiUn 24 hourr.
(3)
The re.xtor shall be scrammed from any operating i
conditKa if the pool temperature reaches 110 F.
Power operation shall not be resumed until the pool temperWura is reduced below the normal power operation limit specified in (1) above.
(4)
Dunng reactor isolation cOndit;v6s, the reactor pressure vessel shall be dopiossurized to less than 200 psig at nemial cooldown rates if the pool temperature reaches 120 F.
2.
Pnmary containment integnty shall be demonstrated in 2.
Pnmary contammont integnty shall be mamtained at all accordance with the requirements of 10 CFR 50 Appendx tunes when the reactor is entical or when the reactor water J. The FitzPatnck plant specsfic test conditions and temperature is above 212*F, and fuel is in the reactor exemphons are as follows:
vessel, except while performing low power physics tests at sin Ospiseric pressure at power levels not to exceed 5 a.
Type A Test (Pnmary Contamment Integrated MWt.
Leakage Rate Test) 1.
The test parameterswpiscabieto theType A test are as follows:
Pa = 45 psig.
La = 1.5 weight %/24 hrs.
l Amendment No.16 l
166 o
JAFNPP 4.7 (cont *d) 2.
The acceptance criteria for the Type A test is as follows:
The measured leakage rate (Lam) shall be less than 0.75 La of the contamed air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at the test pressure Pa.
3.
Exon-@6 from 10 CFR 50 Appendix J with regard to the Type A test are as follows:
a.
Three Type A tests shall be posiviniod, at approximately equal intervals, dunng each 10-year serwce penod.
b.
AType A test does not need to be l
conducted dunng the 10-year plant ISI outage prowded that speciTG7 4.7.A.2.a.3.a above is mel b.
Type B Test (Local Leakage Rate Test) 1.
The test ccii6divis applicable for Type B tests are as follows:
a.
All Type B tests shall be pasivinied by local pneumahc pressurization of the containment penetrations,edher ediwdually or in groups, at a pressure retless than Pa,and the gas flow to mamtain Pa shall be measured.
Amendment No.
167
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JAFNPP 4.7 (cont'd) 2.
Type B Tests of Arriocks a.
Type B tests of airlocks shall be ccaducted at an internal pressure of not less than 45 psig (Pa). The overall leakage rate for the anlock shall be less than or equal to 268 SCFD. Airlock tests shall be conducted:
1.
Every six rnonths.
2.
Prior to restoration of containment integrity,when maintenance has been performed on the airlock which could affectits sealing capability.
3.
Within three days of opening the airlock,when containment integntyis required and maintenance has been perfsined on the airlock which could affect its sealing capatAty.
b.
Ariock seais shall be tested at a pressure not less than 45 psig. The seal leakage rate shall be less than or equal to 120 SCFD. Airlock seal tests shall be conducted:
1.
Prior to restoration of contdin6.ent integnty. If maintenance wtwch could affect seahng c,apstility was peiisined the entire airlock shall be tested as required by 4.7.A2.b_2.a.
Amendment No.
168
JAFNPP 4.7 (cont'd) 2.
Within ttwee days after opemng theawlock,whencorG.wid integnty is required.
3.
Once every three days,du:ing penods of frequent Orming when containment integrity is required.
3.
Exemptions from 10 CFR 50 Appendix J with regard to Type B tests are as follows:
a.
Type B tests, (except tests for awfocks),
shall be F73hamed once per operating cycle.
b.
Type B testog of arlocks shall be rmric medinaccordancewith speoficahon 4.7.A2.b2 above.
Amendment No.
169
- ~ _ -.,
JAFMPP
~
4.7 (cont *d) c.
Type C Test (Local Leakage Rate Test of Code,o,e.it isotahon Valves) 1.
The test condihons apphcable for Type C tests are as follows:
a.
Type C tests shall be performed by local pressurizahon. The pressure shall be appbedin the same direchon as that when the valve would be required to perform its safety funchon, except as listed in Table 4.7-2, unless it can be determoed that the results from the tests for a pressure applied in a different direchon will provide equmulent or more conservative results. Each valve to be tested shallbe closed by normal operation and without any prehmmary exercismg or adjtmoia&
b.
_ Valves, unless pressurized with fluid from a seal system, shall be pressurized with air or rwtrogen at a pressure of Pa, and the gas flowto mantain Pa shall be measured.
Amendment No.126 170
JAFNPP 4.7 (cont'd) 2.
SpecialType C Tests a.
Theleakage ratefor contamment isolabon valves 10AU468A,B (penetration X-13A, B) for Low Pressure Coolant Ir.jection System and 14AOV-13A, B (penetration X.16A, B) for Core Spray System shall beless than 10 cubicfeet per mmute per valve (pneumahcally tested at 45 psig with amtwent temperature) or 10 gallons per mmute per valve (hydrostabcally) tested at 1000 psig with amtnent temperature.
b.
Main Steamisolabon Valves (MSIV) 1.
MSIVs may be tested at a reduced pressure of Pt=25 psig.
2.
The allowableleakage rate for any one MSIV shallbeless than 11.5 standard cube feet per hour (SCFH) when tested at Pt=25 psig.
3.
A cuindion factor equalto shall be used to multiply the reduced pressureleakage rates for the MSIVs prior to summing with theleakage rates for allother penetrations and valves subject to Type B & C tests.
Amendment No. ( 134 171
~.
4.7 (cont'd) 3.
Exemphons for 10 CFR 50 Appendix J with regard to Type C testmg are as follows:
a.
Type Ctests shall be performed once per operating cycle, b.
Valves wtuch are sealed with fluid from a seal system, such as the hquid in the suppression C.cs isr,shall not be tested. See Table 4.7-2 for the list of valves.
c.
The MSWs are tested at a reduced pressure (Pt), and a correchon factor is apphed to the measuredleakage rate in accordance with specification 4.7.A.2.c2.b above.
d.
The combmedleakage rate corrected to Pa for all penetrabons and valves subject to type 8 and C tests shall be less than 0.00 la. Leakage from contamment isolation valves that are sealed with fluid from a sealsystem may be excluded when C_n-a-ay the combmed'@ rate provided that the installed isolahon valve seal-water system fluidinventoryis sufficsent to assure the sealing function for at least 30 days.
Amendment No.f,1dM 172
JAFNPP O
e THIS PAGEINTENTIONALLY BLANK 1
1 1
Amendment No. p 173 (next page is 176)
JAFMPP 4.7 BASES I
A.
Primary Cord 6riirierd The water in the suppression chc.iiber is used only for cooling The dessgn basis loss 4 coolant accident was evaluated in in the event of an csc(idwin, i.s., it is not used for normal FSAR Sechon 14.6 incorporating the pnmary containment operation; therefore, a daily check of the temperature and maxwnum allowable accident leak rate (La) d 1.5 percent / day.
l volume is adequate to assure that adequate heat removal The isr.6y5;5 showed that with the leak rate and a standby gas capability is present.
treatment system filter elliciency d 99 percent for halogens,99 pwmW W assuming the W product The primary containment preoperahonal test pressures are release frachons stated in TID-14844, the maximum totsi whole N Med m Wncm pree body W M h b about OW ran W h maxwnurn i
respyise corresponding to the design basis loss-of<:oolant WW about 11.4 ran m de W w n d. The' peak drywell pressure would be about 45 psig an exposure duh N h h WW h which would rapicNy reduce to 27 psig withen 30 sec. following that would occur over a 30< fay period is 325 rem at the the pipe bre Following the pipe break, the suppression d the k p zone W. h,N h chamber pressure rises to 26 psig within 30 sec, equalizes with are h maxh MM k Win N W M drywell pressure and thereafter rapidly decays with the drywell d a design basis loss-of-coolant accident. These doses are pressum decay 04).
also based on the assumphon of no holdup in the secondary The design pressure d the drywell and suppressson chimiemi is containment, resulhng in a sirect release of fission products
-l 56 psig(15). The design basis accident leakage rate (Ld) is 05 from the pnmary containment through the filters and stack to percent / day at a pressure of 45 psig. As pointed out above, the envrons. Therefore, the specified pnmary contamment the drywell and suppression chamber pressure followng an leak rate and filter efficiency are conservative and provide accident would equalize fairfy rapidly. Based on the primary addibonal margin between expected offsste doses and containment pressure response and the fact that the drywell
.10CFR100 guidelines.
and suppression chessibei function as a unit rather than the individual components separately.
Amendment No.
193
I Iim IMI un u W
~.
4.7 BASES (cont'd)
In accordance with Appendix J paragraph ill A5(b)(2), the h Wgete mmm W W m measured leakage rate (Lam) for the peak pressure Type A test g
j gg gg shall be less than 0.75 La. The primary cu na.in nvin, structure g
g
, operated at a slight positive pressure to continuously monitor (16), and discussed in Queshon 5.4 cf the FSAR. With the is primary containment leakage.
excv t;vi s listed in Table 4.7-2, the system cu evin 6 to the As most leakage and deterioration of integnty is expected to latest Cui..is5;00 guidehnes (17). The exceptions stated in occur through penetrabons, especially those with resilient Table 4.7-2 are necessis y since additional requrements were seals, a periodic leak rate test program of such penetrations is added alter the system was designed.
conducted at the peak pressure of 45 psig to insure not only The exa Ain WW 4.7M Mme h h M
age mmains accept @ hppM N requirements of 10 CFR 50 Appendix J. In accordance with sealing materials can withstand the accivain pressure. The NRC approved exa ipiiv 6 from Appendix J, the requrements Main Steam isolahon Valves (MSIV) are tested by pressurizing WMWTN WG-m W the volume between each pair of valves at a reduced pressure of 25 psig. Higher pressure may cause the inboard valve to B.
Standby GasTreatment System and unseat, resulting in artificially high measured leakage rate. For C.
Secondi=y Contamment airlock leak test, a seal test at the peak pressure could be substituted for the complete arlock test, if no mamtenance inshahng reactor building isolabon and operation of the Standby work is done which could affect the seahng cay &t,;;ity of the Gas Treatment System to maintam at least a 1/4 in. of water Vacuum within the secondary containment provides an arriock.
adequate test of the opershon of the reactor Amendment No. 97,134 194
ATTACHMENT 11 SAFETY EVALUATION FOR PROPOSED TECHNI5KI.6GES REGARDING CONTAINM (JPTS-84-012)
New York Power Authority JAMES A. FIT 2 PATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 i
7
i 1 SAFETY EVALUATION Page 1 of 7 1.
DESCRIPTION OF THE PROPOSED CHANGES The proposed changes to the James A. RtzPatrick Technical Specifications replaces Specification 4.7.A.2 on pages 186 through 175, and revises the associated Bases on pages 193 and 194. Technical Specification 4.7.A.2 provides the requirements for performing Primary Containment integrated and 1.ocal Leakage Rate Tests.
Specification 4.7.A.2 is replaced in its entirety. The replacement specifications are shown in. All of the text on pages 173a through 175 has been either deleted or reloca*.ed.
These pages shall be removed from the Technical Specifications. The changes to the Bases are described below.
Page 193, Bases for Specification 4.7.A THIRD PARAGRAPH Insert *(Ld)* after
- design basis accident leakage rate."
FOURTH PARAGRAPH Insert *(La)* after
- allowable accident leak rate."
Replace *.97" with *0.97.*
Page 194, Bcses 4.7 (cont'd)
FIRST PARAGRAPH Relocate this text to page 193 to complete this paragraph.
SECOND and THIRD PARAGRAPHS Replace these paragraphs with the following:
In accordance with Appendix J paragraph I!IA.5(b)(2), the measured leakage rate (Lam) for the peak pressure Type A test shall be less than 0.75 La. The primary containment is operated at a slight positive pressure to continuously monitor primary containment leakage.
FOURTH PARAGRAPH Insert the following after the first sentence in the right column:
The Main Steam Isolation %Ives (MSIV) are tested by pressurizing the volume between each pair of valves at 25 psig. Higher pressure may cause the Inboard valve to unseat, resulting in artificially high measured leakage rate, insert the following at the end of Bases 4.7.A:
1
)
I
[
Attactanent il SAFETY EVALUATION Page 2 of 7 The exemptions in specification 4.7.A.2 devista from the requirements of 10 CFR 50 Appendix J. In accordance with NRC approved exempt.bns from Appendix J, the requirements set forth in the Technical Specifications take precedence.
11.
PURPOSE OF THE PROPOSED CHANGES The purpose of the proposed changes is to revise the Technical Specifications to reference current NRC regulations conceming primary containment leakege rate testing. The FitzPatrick Technical Specifications were originally written prior to the adoption of 10 CFR 50 Appendix J.
Therefore, to assure that the primary containment would be leak tested, many of the requirements of Appendix J were incorporated directly into the Specifications. Minor exceptions i
from Appendix J were then approved by the NRC as part of the initialissuance of the Technical Specifications, in order to avoid unnecessary duplication of requirements, the portions of Appendix J currently written into the Technical Specifications are removed. Those specifications which constitute previously approved exemptions are retained.
The following table provides a cross reference between the existing Technical Specification l
4.7.A.2 and corresponding sections of 10 CFR 50 Appendix J. This table demonstrates that all testing requirements that are being removed by this amendment are still effective by the requirements of Appendix J.
Technical 10 CFR 50 Notes or Specification Appendix J Comments i
4.7.A.2.a(1) lil.A 4.7.A.2.a(2) lit.A 1(b) 4.7.A.2.a(3) lli.A.1(c) 4.7.A.2.a(4) til.A.1(d) 4.7.A.2.a(5) lli.A.3(a) 4.7.A.2.a(6) lil.A.3(b) l 4.7.A.2.a(7)(a) til.A.4(a)(1)(l) 4.7.A.2.a(7)(b) lli.A.4(a)(1)(ii) 4.7.A.2.a(7)(c) lli.A.4(a)(1)(iii) 4.7.A.2.a(8) lil.A.5(a)(2)(b)(1) i and Ill.A.5(b)
The acceptance criterionis being retained and clarified in the revised Specifications.
4.7.A.2.a(9) lli.A.5(a)(1)&(2) 4.7.A.2.a(10)
Ill.A.6(a) and (b) 4.7.A.2.b(1) lli.B.2 The test method is being retained in the revised Specifications.
4.7.A.2.b(2) lli.B.3(a) 4.7.A.2.c(1)
Ill.C.1 References to Table 4.7 2 are being retained.
4.7.A.2.c(2) lil.C.2 The test me; hod is being retained.
4.7.A.2.c(3)
This specification is being retained.
4.7.A.2.c(4)
References to Table 4.7 2 are being reiained.
~_
V Attachment II'
-i
_ SAFETY EVALUATION t
.Psge 3 oi7' i
Technical 10 CFR 50 -
Notes or Spectfication Appendix J.
Comments f
4.7.A.2.c(5) lit.C.3 and Ill.C.3(b)
The RtzPatrick seal water system
- (suppression pool) rW not be at a L
- pressure of 1.10 Pc 4.7.A.2.d(1)
An existing error it w;m;.cification is being corrected.
- 4.7.A.2.e(1)
Ill.D.1 and Ill.D.1(b)
. This specification is being revised '
as discussed below. -
4.7.A.2.e(2) lil.D.2 This specification is being revised as discussed below..
4.7.A.2.e(5 Ill.D.2(b)(i)
These specifications are being; thru thru-retained.
.i 4.7.A.2.e(4)(c) '
lil.D.2(b)(iv) 4.7.A.2.e(5) lli.D.3 This specification is being revised -
as discussed below..
I.
4.7.A.2.e(6)
.This specification is being revised -
as discussed below.
d.7.A.2.f IV.A L
1 The Specifications noted above as being revised _consti+ute new exemptions from 10 CFR 50 -
1 l
Appendix J. These exemptions provide greater flexibility in scheduling Type. A, B and C Integrated and local leak rate tests. Specifice'!y. the Authority is requesting that the Type B and l
C test surveillance in+erval be revised to or,ce per operating cycle, eliminating the.24 month maximum interval constraint. This will eliminate the need to shut down solely.to perform
- surveillance testing. In addition, the Type A test surveillance interval.ls being revised such th'at the third test of each set need not correspond to the 10. year Inservice inspection outage.
r Appendix J and the current Technical Specifications allow for reduced pressure periodic Type A ILRTs. During the pre. operational ILRT at FitzPatrick, both peak pressure and reducer' 'ressure tests were performed. The Authority was unable to correlate the results from the tr
- ts and, i
therefore, has performed only peak pressure tests for the periodic ILRTs. Theref.
.ne Bases 3
concerning reduced pressure ILRT are being deleted from the Technical Specifications.
The Main Steam Isolation Valves (MSiVs) for most BWRs including the FitzPatrick plant are tested at a reduced pressure and have individual valve leakage rate acceptance criteria. This
- test condition is referred to in Technical Specification Table 4.7 2 " Exceptions to Type C tests."
The proposed change more clearly describes this existing exception to Appendix J In the text of.
the Technical Specificsons and provides an associated Basis.
The Type A test accep'.ance criteria currently contained in Specification 4.7.A.2.a(8) is being revised to conform to Appendix J. The existing specification was written to support the pro-operational test and, therefore, the acceptance criteria of 0.75 La and not greater than Ld was appropriate and consistent with Appendix J, paragraph lil.A.4(b)(2). This technical specifications l3 being revised to less than 0.75 La, consistent with the periodic test acceptance criteria of Appendix J, paragraph Ill.A.5(b)(2).
t i
t
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a-m.
Attachment ll SAFETY EVALUATION l
Page 4 of 7 in the past, tNs same specification had been interpreted to state that the numerical value of the allowable leak rate, La, was 0.5 weight percent of the contained air volume per day and, l
therefore, the Type A acceptance criteria was 0.375 percent per day (0.75 La). As discussed in the Technical Specification Bases, FSAR, in letters from the FitzPatrick plant Architect / Engineer, and in the FitzPatrick plant original licensing correspondences (References 1,3 and 4), the i
1 correct value of La is 1.5 percent per day and that 0.5 percent per day represents the value of the design leakage rate, Ld. The values of La and Ld are being claritied in the revised specifications.
The three affects of this clarification are as follows: 1) The value of the Type A test leakage i
acceptance criteria of 0.75 La increases to 1.125 percent per day; 2) The value of the combined Type B & C test leakage acceptance criteria of 0.6 La would increase to 0.9 percent per day; and
- 3) The value of the "As-foundtType A test acceptance criteria (when required) becomes 1.5 percent per day (La). These values are consistent with the FitzPatrick FSAR accident analysis and the requirements of Appendix J. This change has no effect on the testing program beyond the revision of the acceptance criteria. These changes make 11 less likely that the test results would require the test to be declared a failure. These new values are consistent with the FSAR analyses and the requirements of 10 CFR 50 Appendix J and do not constitute an increase in the allowable leakage rates as analyzed in the FSAR. Therefore, these changes have no affect on plant safety.
Ill.
EXEMPTION REQUEST As part of the proposed changes to the Technical Specifications, and in accordance with 10 CFR 50.12(a), the Authority requests two changes which constitute exemptions to the requirements of 10 CFR 50 Appendix J. These exemptions are described below:
1.
Surveillance Interva! for Performing Type A Tests 10 CFR 50 Appendix J lill.D.1.(a) reau!res that three Type A tests shall be conducted at approximately equal intervals during each ten years service period. In addition, the third test shall be conducted while the plant is shut down for the 10 year plant inservice -
inspectinn outage.
No tangible link exists between the third ILRT and the ISI inspections performed during 10-year inservice inspection outage. The Authority, therefore, requests an exemption from the requirement that the third Type A test in each ten year service period correspond with the 10-year inservice inspection outage.
i 2.
Surveillance Interval for Performing Type B and C Tests 10 CFR 50 Appendix J Sill.D.2.(a) and 6til.D.3 both require that local leak rate tests (Type B and C LLRTs, respectively) be performed during each shutdown for refueling,.but in no 1
case at intervals greater than two years. This requirement was reasonable and posed no a
hardships when typical operating cycles were from one year to 15 months in length. Most p' ants now have longer operating cycles to improve overall fuel economies and plant-j availabilities.
Currently, the FitzPatrick plant has 18 month operating cycles and is planning to extend the cycle length to 24 months starting with Cycle 11 in 1991. With the advent of longer-operating cycles, it becomes more !!kely that the two year limit may expire while the plant is still at power. To avoid a forced shutdown solely to perform Technical Specification
Attachment II' e
SAFETY EVALUATION -
Page 5 of 7 surveillances, the Authority is requesting an exemption from the two year limit on the Type B and C LLRT surveillance interval. Specifically, the Authority, requests that the surveillance interval be once per operating cycle with no additional constraints.
10 CFR 50.12(a) indicates that the Commission may grant exemptions if special circumstances are present. The circumstances which apply to the proposed changes are discussed below.
Circumstance (ii) states:
Application of the regulation in the particular circumstances muld not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule; The underlying purpose of the schedules contained in 10 CFR 50 Appendix J lill.D.1.(a),
Ill.D.2.(a), and Ill.D.3 is to assure that containment testing is performed such that valve degradation is identified and repaired before containment leakage exceeds acceptable levels.
This purpose is met through the Technical Specification requirement that Type A testing be performed three times every 10 years and that Type B and C testing be performed during each refueling o. stage. There is no tangible link between the ILRT and the ISI inspections performed during 10-year inservice inspection outage. Therefore, this' requirement is ennecessary to achieve the purpose of Appendix J.
Circumstance (iii) states:
Compilance 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.
i When Appendix J was adopted, cycle lengths of one year were standard. Therefore,'the 24 j
month limit on Type B and C tests posed no hardships. With extended cycle lengths of up to 24 I
months, this requirement may now require plant shutdown solely.to conduct Type B and C l
surveillance. This forced shutdown and its associated costs constitute hardships significantly in excess of those contemp!?ted when Appendix J was adopted. The proposed exemption would also facilitate outage work scheduling, since it would not be necessary to perform a Type A ILRT specifically during the 10 year inservice inspection outage.
4 IV.
IMPACT OF THE PROPOSED CHANGES The most significant aspect of the proposed change is referencing the test requirements of 10 CFR 50 Appendix J instead of listing them in the Technical Specifications. This results in the I
elimination of unnecessary redundancy and the requirement to comply with potentially conflicting requirements. An example of conflicting requirements occurred with respect to the Type A data analysis methodology. In recent ILRT tests, the Authority had to perform both the
" mass point" and " total time" analyses, because, prior to the November 15,1988 revision of Appendix J, the " mass point" technique was required by the Technical Specifications and the
" total time" analysb was required by reference to the ANS N45.4 standard in Appendix J.
The Authority is aware that the NRC is preparing a substantial revision to Appendix J. By j
referencing Appendix J directly, the Authority can implement these changes to the regulations without also having to meet the requirements of the existing Appendix J as contained in the Technical Specifications. In addition, exemptions to Appendix J can be granted without 2
^
- Attachment ll SAFETY EVALUATION-Page 6 of 7 amendments to the Technical Specifications. Since the need for an exemption often arises with little advance notice, the need to process simultaneous amendments to the Technical Specifications on an emergency basis is avoided. This reduces unnecessary burden on both the Authority and the NRC staff.
-The Authority wishes to retain those portions of the existing Technical Specifications which constitute previously - approved exceptions and exemptions from Appendix J.
These specifications remain in effect in the revised Specification 4.7.A.2.
In addition to these -
exemptions, the Authority is requesting new exemptions regarding scheduling of Type A, B and C leak rate tests. Ac discussed in Section til above, these exemptions have no significant impact on [ ant safety, V.
EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION.
Operation of the FitzPatrick plant in accordance with the proposed amendment would not involve a significant hazards consideration as stated in 10 CFR 50.92, since it would not:
1.
Involve a significant increase in the probability or consequences of an' accident.
previously evaluated.
The proposed specifications do not involve changes to plant equipment or the FitzPatrick plant's ability to prevent or mitigate accidents. The changes are administrative in nature, since all of the requirements being removed from the Technical Specifications will continue to be in effect by their presence in 10 CFR 50 Appendix J. The proposed changes remove the redundancy of having multiple sources of identical test requirements. The overall purpose of the specifications under revision is to assure that the containment system is tested on a routine basis to verify and assure its leak tight integrity. No change is being made which can affect this purpose. Therefore, there is no increase in the probability or consequences of an accident previously evaluated.
2.
create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes concern the surveillance test requirements for the FitzPatrick plant containment systems. This testing program cannot initiate any type of accident. The containment testing program is designed to assure that the assumptions of the FSAR accident analysis with regard to containment performance are met.
3.
Involve a significant reduction in a margin of safety.
As discussed above, the proposed changes are purely administrative in nature and remove unnecessary redundancy between the FitzPatrick Technical Specifications and the requirements of 10 CFR 50 Appendix J. Referencing Appendix J directly allows the Authority to implement changes to the regulations without either having to amend the Technical Specifications or having to comply with multiple requirements. The only change to the containment testing program concerns the scheduling of Type A, B and C leakage rate tests. These changes allow for increase flexibility in the scheduling of the tests. No change is made to the testing program which can affect any margin of safety.
l
l 0
o Attachment ll -
1 SAFETY EVALUATION l
Page 7 of 7 VI.
IMPLEMENTATION OF THE PROPOSED CHANGE Implementation of the proposed changes will not impact the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes impact the environment.
)
Vll.
CONCLUSION The change, as proposed, does not cons 0tute an unreviewed safety question as defined in 10 j
CFR 50.59. That is, it:
a.
will not change the probability nor the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report; J
b.
will not increase the possibility of an accident or malfunction of a type different from any previously evaluated in the Safety Analysis Report;.
c.
will not reduce the margin of safety as defined in the basis for any technical specification; d.
does not constitute an unreviewed safety question; and e.
Involves no significant hazards consideration, as defined in 10 CFR 50.92.
I
. Vill.
REFERENCES l-1.
James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, Sections 5.2.4.4 and 14.6.1.3.5.
2.
James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements.
3.
LeBeouf, Lamb, Leiby, & MacRae Letter to P. A. Morris (AEC), dated March 10,1972, providing Amendment No. 5 to Application for License with Supplement No. S to the FitzPatrick FSAR, Response to AEC letter, dated 11/29/71, Question 5.10.
4.
Stone & Webster Engineering Corp. letter, B. C. Kuechler to R. Pasternak (PASNY), dated April 4,1980, Response to NRC inspection report.
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