ML20039F832
| ML20039F832 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 01/11/1982 |
| From: | Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-***, TASK-TM JPN-82-7, NUDOCS 8201130440 | |
| Download: ML20039F832 (10) | |
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POWER AUTHORITY OF THE STATE OF NEW YORK 10 COLUMeus CIRCLE NEW YORK. N. Y. too19 E 212 5 397 6200 G EOR,G,E T; m E R R Y opennessee optican TRUSTEES JOHN W. BOSTON JOHN S.DYSON Pas som noCEDunst a rtaFonMANCE GECRGE L. ING ALLS JOSEPH R. SCHMIEDER vsC E CMA6 AMAN at DE, S Chit F RlqHARD M, FLyNN January 11, 1982
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Director of Nuclear Reactor Regulatio,1
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U. S. Nuclear Regulatory Commission
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Cac Attention:
Mr. Thomas A.
Ippolito, Chief b
Operating Reactors Branch No. 2 Division of Licensing a
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Subject:
James A. FitzPatrick Nuclear Power Plant w
p Docket No. 50-333 NUREG-0737 Post-TMI Requirements Submittals and Modifications Required by January 1, 1982
Reference:
NRC letter, D.G. Eisenhut to all Licensees of Operating Plants, dated October 31, 1980
Dear Sir:
contains the Power Authority's response to the following NUREG-0737 items which require submittals or modifications by January 1, 1982:
II.B.l.3 Reactor Coolant Sys, tem Vent Procedures II.B.2.2 Plant Shielding Modifications II.B.3.2 Postaccident Sampling Modifications II.D.l.2.b Relief and Safety Valve Plant Specific Test Report II.F.1.1 Noble Gas Effluent Monitor II.F.1.2 Postaccident Effluent Sampling for Iodine and Particulates II.F.1.3 Containment High-range Radiation Monitor Jfof II.F.1.4 Containment Pressure Monitor j
/ f bh33 KO PDR
. II.F.1.5 Containment Water Level Monitor II.F.1.6 Containment Hydrogen Concentration Monitor II.F.2 Instrumentation for Detcation of Inadequate Core Cooling II.K.3.22 Automatic Switchover of RCIC Suction II.K.3.24 HPCI and RCIC Space Cooling II.K.3.25 Effects of the Loss of Power on Pump Seals II.K.3.28 Qualification of ADS Accueillators II.K.3.30.b Small-break LOCA Model III.D.3.4 Control Room Habitability The following items, including submittals and modifications, are complete or are scheduled for completion during the Reload 4/
Cycle 5 refueling outage currently in progress:
II.B.1.3; II.B.2.2; II.D.l.2.b; II.F.1.3; II.F.1.4; II.F.1.5; II.K.3.24; II.K.3.25; II.K.3.30.b.
Item III.D.3.4 is scheduled for completion during the 1983 refueling outage.
Modifications required by Items II.F.1.1 and II.K.3.22 are scheduled for completion during the current outage.
The unavaila-bility of environmentally qualified equipment may necessitate the installation of partially qualified components in order to meet the implementation dates specified by NUREG-0737.
The installed components will be qualified or replaced when qualified substitutes can be obtained.
Appendix B or NUREG-0737 acknowledges the ac-ceptability of this approach.
Items II.B.3.2, II.F.1.2, II.F.1.6, II.F.2, and II.K.3.28 cannot be completed by the required implementation dates.
Enclosure 1 identifies the reasons for the delays, contains requests for schedule extensions, and provides justification for the extension requests including descriptions of compensating factors.
The Power Authority is preparing a comprehensive schedule of long-term modifications or major work currently forecast for the FitzPatrick plant.
The Authority will furnish this integrated work schedule to the NRC in the near future.
The dates included in this letter have been taken from this integrated modification sche-dule.
In the future, adjustments to the dates mentioned
. within this letter will be provided in the integrated schedule.
If you have any further questions, please do not hesitate to contact us.
Very truly yours, J
P Ba y
enlor Vice President Nuclear Generation cc:
Mr. J. Linville Resident Inspector U.
S. Nuclear Regulatory Commission P. O. Box 136 Lycoming, New York 13093 Mr. Ron Barton United Engineers & Constructors, Inc.
30 S.
17th Street Philadelphia, Pa.
19101
I i
i POWER AUTilORITY OF THE STATE OF 11EU YORK JAMES A.
FITZPATRICK tiUCLEAR POWER PLA14T I
DOCKET 110. 50-333 IIUREG-07 37 POST - TMI REQUIREME!1TS l
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l E!1 CLOSURE 1 to JIiF Page 1 of 7 l
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l II.B.l.3 Reactor Coolant System Vent Procedures The Power Authority provided a detailed description of the JAFNPP RCS venting capability in a letter from P. J. Early to
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D. G. Eisenhut dated December 22, 1979 (J PU-79-6 5 ).
The current status of the JAFNPP RCS venting procedures was provided in a letter from J. P. Bayne dated July 7, 1981 (JPN-81-49).
This letter stated that the generic positions expressed by the BWR Owners' Group, regarding BUR 4 RCS venting, are applicable to the FitzPatrick plant.
This 1
includes the response to URC questions trou D.
B.
Waters
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(BWROG) to D. G. Eisenhut dated April 24, 1981, concerning procedures and HPCI/RCIC operations.
Procedures for venting the JAFNPP RCS are contained in j
F-OP-65 Startup and shutdown Procedure.
The Power Authority is i
also participating with the BWR Owners' Group in the development of emergency procedure guidelines which will address RCS venting through the operation of the HPCI, RCIC,
)
and ADS Systems.
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II.B.2.2 Plant Shielding nodificationa The Power Authority's review of the FitzPatrick plant has l
identified only one plant modification necessary to comply with the NUREG-0737 criteria for this item.
The modification, which consists of repacking valves which currently have teflon l
packing, is scheduled for completion during the refueling i
outage now in progress.
II.B.3.2 Postaccident Sanpling Modifications A Postaccident Sampling System modification to the FitzPatrick plant is_ currently in progress.
Due to delays in obtaining qualified equipment, particularly solenoid valves, additional engineering and procurement necessary to provide an alternate power supply to the system, and the magnitude of the installation, this modification cannot be completed during the current refueling outage.
Therefore, the Power Authority requests an extension of the due date for the completion of this iten to December 31, 1982.
The Power Authority considers that adequate compensating factors exist to justify this extension.
The objective of the permanent postaccident sampling system is to enable the sampling and analysis of high-activity reactor coolant.
This objective is met by existing equipment ano an approved procedure, now in effect and available at the plant for review, for obtaining and analyzing high-activity reactor coolant Page 2 of 7 I
samples.
The existence of this interim capability was identified in a letter from P. J. Early to T.
A.
Ippolito dated January 2, 1980 (JPN-80-1).
II.D.1.2.b Relief and Safety Valve Plant Specific Test Report In a letter, J. P.
Bayne to T.
A.
Ippolito dated September 30, 1981 (JPN-81-80), the Power Authority provided a response to this item.
The Authority's letter endorsed the BWR Cwners' Group final report on the Generic BUR Safety Relief Valve Test Program submitted in a letter. f rom T. J. Dente (BUROG) to D. G.
Eisenhut dated September 25, 1981.
The Authority's letter explained the applicability of the test report to the FitzPatrick plant and stated that the test report demonstrates the integrity of the FitzPatrick SRVs and discharge piping for the conditions specilied in this NUREG-0737 item.
II.F.1.1 Noble Gas Effluent Monitor The design package for this modification is complete and is available at the plant for review.
The noditication is scheduled for completion during the current refueling outage.
However, the equipment being installed riay not meet the environmental qualifications imposed by Regulatory Guide 1.97 Revision 2.
Additionally, concerns have recently been identified regarding NUREG-0737 requirements for adequate range overlap with existing equipment.
The Power Authority is currently working with the vendots to resolve these deficiencies.
The acceptability of this approach is acknowledged in Appendix D of NUREG-0737.
The NRC staff will be kept informe6 of the Authority's progress on this matter.
II.F.1.2 Postaccident Effluent Sampling _Por Iodine And Particulates The Power Authority addressed this item in responsen to NUREG-0578.
In letters from P. J.
Early to D.
G.
Eisenhut dated October 22, 1979 (JPN-79-65) and January 2, 1980 (JPN-80-1), the Authority stated that the existing instrumentation and plant procedures were adequate to satisfy I
the NUREG-0578 item.
Due to the new requirements of NUREG-0737, the Power Authority utilized an expert consultant to re-evaluate this j
f issue.
The report was recently completed and is presently under evaluation.
The Authority's initial review has I
identified potential areas of discrepancy primarily due to the
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different regulatory positions in Regulatory Guides 1.97 and 1
1.3.
The NRC staff will be kept advised on this issue.
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T II.F.1.3 Containment High-Range Radiation Monitor II.F.1.4 Containment Pressure Monitor II.F.1.5 Containment Water Level Monitor The design packages for these modifications are complete and are available at the plant for review.
These three modifications to the FitzPatrick plant are scheduled for completion during the current refueling outage.
II.F.1.6 Containment Hydrogen Concentration Monitor The Power Authority is developing a design package for installation of a hydrogen monitor in the FitzPatrick plant.
However, substantial delays have been encountered in obtaining solenoid valves and qualified electrical, instrumentation and control equipment.
Although the Authority is making every reasonable effort to expedite the procurement of the necessary equipment, this modification cannot be completed during the current refueling outage.
The objective of hydrogen monitoring is to provide the capability to detect the potential for breaching containment, due to hydrogen build up.
The hydrogen and oxygen monitoring equipment now installed in the FitzPatrick plant provides this capability, although it does not meet the requirements of Regulatory Guide 1.97 Revision 2.
Operability of this equipment is assured by Technical Specification 3.7 A.9.
In addition, Technical Specification 3.7.A.6 required containment inerting during power operation.
The FitzPatrick plant also has safety related systems designed to mitigate hydrogen build up in containment.
A qualified hydrogen monitor has been received at the plant.
The Power Authority may return this unit to the ranufacturer and obtain a qualified unit to monitor both hydrogen and oxygen levels in containment.
The additional capability to monitor oxygen would enable the Authority to achieve compliance with Regulatory Guide 1.97, Revision 2 and IE Bulletin 79-01B.
For reasons of material unavailability, the possible addition of an oxygen monitoring capability, and the magnitude of the installation, the Power Authority requests an extension of the due date for completion of this modification until December 31, 1982.
II.F.2 Instrumentation for the Detection of Inadequate Core Cooling The Power Authority is participating in the current BWR Owners' Group activities with regard to this item.
Studies recently completed by technical consultants to the owners' Page 4 of 7
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Group, show that installation of incore thermocouples will not increase the operators' ability to diagnose inadequate core cooling.
The Power Authority considers this finding applicable to the FitzPatrick plant.
The Power Authority is supporting, and will continue to support, the owners' Group efforts to. resolve this item with the NRC staff and to explore other technical alternatives.
When this NUREG-0737 item is resolved, the Authority will review the resolution and notify the NRC of its. intentions.
II.K.3.22 Automatic Switchover of RCIC Suction The Power Authority is currently modifying the FitzPatrick plant to provide automatic switchover of RCIC suction from the condensate storage tank to the suppression pool.
Ilowever,
qualified level switches cannot be obtained in time for installation during the current outage.
Therefore, the Power Authority has scheduled this modification for completion during this outage using available partially qualified switches.
The switches will be replaced when qualified substitutes can be obtained.
II.K.3.24 HPCI and RCIC Space Cooling A description of the Reactor Building Ventilation System, which provides cooling for the HPCI and RCIC equipment areas, is contained in Section 9.9.3.3 of the FitzPatrick FSAR.
This section states that Reactor Building Elevation 227'-6", where the HPCI and RCIC equipment is located, is supplied with sufficient outside air to cool the area during normal operation, when this ventilation system is not operating, area cooling is accomplished by unit coolers.
The PSAR states that the unit coolers have sufficient capacity to handle the entire heat load without outside air.
The unit coolers are 100% redundant and separately located.
Each cooler is connected to a separate emergency power supply and receives water from separate loops of the Emergency Service Water (ESW) System.
The ESW System is also provided with emergency power.
As a result of fire protection modifications, a fireproof enclosure has been constructed around the RCIC pump.
This enclosure is equipped with two exhaust fans with dampers and two intake dampers.
One fan provides normal cooling and is powered f rom a non-emergency source.
The other fan provides automatic emergency cooling and is powered from the same Page 5 of 7-
electrical divicion as the RCIC system.
The dampers are normally opsn cnd cloce only in case of fire inside the RCIC enclosure.-
The entire ventilation system is automatic and fully redundant, with annunciation in case of nalfuntion or failure.
The air drawn into the enclosure by the fans is from *.he general area.
This air is normally supplied by the Reactor Building ventilation System which is backed up by the unit coolers as described above.
The unit cooler nearest the RCIC enclosure is powered from the same electrical division as the RCIC system.
The existing FitzPatrick !!PCI and RCIC cpace cooling equipment satisfies the acceptance criteria of this UUREG item.
Therefore, no modifications to the plant are required.
II.K.3.25 Effects of the Loss of Power on Pump Seals The Power Authority responded to this requirement in a letter, from J. P.
Bayne to T.
A.
Ippolito dated July 7, 1961 (J PN-81 -4 9 ), which endorsed a BWR Owners' Group generic analysis as applicable to the FitzPatrick plant.
In addition, the FitzPatrick recirculation pump seals are cooled by both the Reactor Building Closed Loop Cooling Water System (RBCCW) and the Recirculation Pump Mini-Purge System (RPMP).
RBCCW supplies cooling water to the recirculation pump seal coolers during normal operation.
Upon loss of offsite power, the Emergency Service Water System (ESW) supplies the.
seal coolers.
The ESW System is powered by onsite emergency power.
The Mini-Purge System supplies cool seal purge water directly to the recirculation pump seals during normal operation and upon loss of offsite power.
The Mini-Purge Systen receives water from the Control Rod Drive Pumps which are powered by onsite emergency power.
Therefore, the existing FitzPatrick design meets the intent f 2 of the NUREG without modification and the Power Authority considers its efforts on this item to be complete.
II.K.3.28 Qualification of ADS Accumulators s
The Power Authority has participated in BUR Ownerc' Group.
generic review of this item and has only recently received'the final result of this study.
The Authority has had insufficient' time to review the study, to determine if plant modificati.cas are required, and complete the modifications by the required date.
In view of the Power Authority's efforts to complete all of the post-TMI requirements and the resulting burden on the Page 6 of 7 s
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Authority's 4taff, the Aythority requests an extension of the January 1, 1952 completion date for~this item.
The Power Authority proposes to review the results of the Owner's Group ef for ts and respond to t.he URC by April 1, 1982.
This response will include a description of the nodifications, if any, necessary to comply with'this requirement and a schedule for their implementation.
II.U. 3.30.b.
Small-breck LOCA Model The General Electric Company provided a response to this item in a letter fron R. ii. Buchholz (Cl:) to D. G.
Cicenhut dated June 26, 1981..This response demonstrated that the existing GE cmall-L'reak h0CA model is in' full compliance with 10 CFR 50 Appendix K and therefore saticities this HUREG item.
III.D.3.4 Control Room liabitabilig The Power Authority provided an analysis of the FitzPatrick control. room in a lettet f r ora J. p. Bayne to T, A.
Ippolito dated August 13, 1981 (JPN-8.1-6 0 ).
'1his letter committed to the performance of a control roon precautization test and the installation of additional breathing apparctus by January 1, 1982.
These tests and raodificat,ionc are scheduled for completion during the current refueling outage.
This letter also committed to install a redcadant damper.
This modification is scheduled for completion during the 1983 refueling outage.
The Authority also ce':amitted. to change the FitzPatrick Technical Specificatior.s to reghire control room makeup air canacity tests.
A request for.a change to the~ Technical Specificationn will be submitted to the NRC in the near future.
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