ML20044B744

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Requests Addl Info in Order to Complete Review of Primary Containment Pressure Limit for Plant within 90 Days of Ltr Date
ML20044B744
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 03/01/1993
From: Mccabe B
Office of Nuclear Reactor Regulation
To: Ralph Beedle
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
TAC-M85793, NUDOCS 9303030357
Download: ML20044B744 (5)


Text

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I March 1, 1993 Dacket No. 50-333 DISTRIBUTION:

Docket File NRC & Local PDRs PDI-l Reading SVarga JCalvo RAcapra CVogan BMcCabe Mr. Ralph E. Beedle OGC RBarrett, 8/H/7 Executive Vice President, Nuclear JKudrick, 8/D/l JMonninger, 8/D/1 Generation CCowgill, RGN-1 ACRS (10)

Power Authority of the State of New York i

123 Main Street White Plains, New York 10601

Dear Mr. Beedle:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PRIMARY CONTAINMENT PRESSURE LIMIT - JAMES A. FITZPATRICK NUCLEAR POWER PLANT (TAC NO. M85793)

Based on our ongoing review of the Primary Containment Pressure Limit (PCPL) for the James A. FitzPatrick Nuclear Power Plant, we have identified the need for add'tional information in order to complete the review. We, therefore, request that you provide a response to the questions enclosed.

In order to facilitate our current review schedule, we request that you provide written responses to the questions within 90 days of the date of this letter.

This requirement affects one respondent and, therefore, is not subject to Office of Management and Budget review under P. L.96-511.

S i n<.. o rel y,

Original Signed By:

Brian C. McCabe, Project Manager Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ enclosure:

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March 1, '1993 l

l Docket No. 50-333-i i

Mr. Ralph E. Beedle

'l Executive Vice President, Nuclear i

Generation i

Power Authority of the State of New York

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123 Main Street

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White Plains, New York 10601

Dear Mr. Beedle:

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PRIMARY CONTAINMENT

.i PRESSURE LIMIT - JAMES A. FITZPATRICK NUCLEAR POWER PLANT (TAC NO. M85793) j Based on our ongoing review of the Primary Containment Pressure Limit (PCPL)4 f

fortheJamesA.FitzPatrickNuclearPowerPlant,wehaveidentifiedtheneed i

for additional information in order to complete the review. We, therefore, request that you provide a response to the questions enclosed.

In order to i

' facilitate our current review schedule, we request that you provide written responses to the questions within 90 days of the date of this letter.

i This requirement affects one respondent and, therefore, is not subject to l

Office of Management and Budget review under P. L.96-511.

l t

Sincerely,

)

i hNd4.'

Brian C. McCabe, Project Manager Project Directorate I-1 t

Division of Reactor Projects - I/II

' W Office of Nuclear Reactor Regulation 4 Q,. *

Enclosure:

?

Request for Additional j

Information

'I cc w/ enclosure:

See next page j

I

Mr. Ralph E. Beedle James A. FitzPatrick Nuclear Power Authority of the State of New York Power Plant cc:

Mr. Gerald C. Goldstein Ms. Donna Ross Assistant General Counsel New York State Energy Office Power Authority of the State 2 Empire State Plaza of New York 16th Floor 1633 Broadway Albany, New York 12223 New York, New York 10019 Resident Inspector's Office U. S. Nuclear Regulatory Commission Post Office Box 136 Lycoming, New York 13093 Mr. Harry P. Salmon, Jr.

Resident Manager James A. FitzPatrick Nuclear Power Plant Post Office Box 41 Lycoming, New York 13093 Mr. J. A. Gray, Jr.

Director Nuclear Licensing - BWR Power Authority of the State of New York 123 Main Street White Plains, New York 10601 Supervisor Town of Scriba Route 8, Box 382 Oswego, New York 13126 Mr. John C. Brons, President Power Authority of the State of New York 123 Main Street White Plains, New York 10601 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406

l ENCLOSURE k

JAMES A. FITZPATRICK PRIMARY CONTAINMENT PRESSURE LIMIT REQUEST FOR ADDITIONAL INFORMATION TAC NO. M85793 BACKGROUND A

The primary containment pressure limit (PCPL) is defined as the lowest pressure of the following:

- pressure capability of the contsinment

- maximum containment pressure for vent valves to open and close

- maximum containment pressure safety relief valves can open and remain open

- maximum containment pressure for reactor pressure vessel vent valves to open and close for containment flooding t

In the NRC's Safety Evaluation Report (SER) (September 12,1988) approving i

Revision 4 of the BWROG Emergency Procedure Guidelines (EPG), the NRC (page 16) stated that:

The staffs' stated goal is to limit venting to a "last resort" action.

The major staff concern has centered on the appropriate containment pressure for venting. As a result, the venting pressure should be established to as high as reasonably achievable.

If PCPL is less than the design pressure, the licensee must submit just iication and the staff will evaluate on a case by case basis. Accordingly, a reasonable effort should be made by each licensee to increase the primary containment pressure limit as high as practical, e.g.,

perform adjustments to the pneumatic operating pressure of the SRVs, and consideration for improving vent valve operability.

OVESTIONS 1.

Provide a more thorough rationale for the selected PCPL including justification for not increasing the value to as high as practical.

Discussion: At FitzPatrick, the PCPL (44 psig) is less than the primary containment design pressure (56 psig).

In a letter dated September 25, 1990, the Power Authority of the State of New York (PASNY) provided their basis for setting the PCPL below the primary containment design pressure. The PCPL value at FitzPatrick was chosen based on the capability of drywell vent valve 27-A0V-Il4. The wetwell vent valves have the capability to vent at substantially greater pressure (79.3 psid). The NRC staff does not believe that PASNY has provided sufficient basis.

Venting, even if it results in some radiological consequences, should only be undertaken as an extreme means to prevent core melt or as a last resort measure to prevent irreversible and unpredictable rupture of the

l containment, which could otherwise lead to a larger release.

The staff indicated in the EPG SER that a potential negative aspect associated with venting is the possibility that venting will be performed unnecessarily.

Unnecessary venting is possible because venting is an anticipatory step and may be undertaken prior to subsequent recovery of other systems.

A lower value selected for the PCPL would reduce the amount of time provided for recovery of systems which could eliminate the need for venting.

PASNY selected the FitzPatrick PCPL based on the capability of the drywell vent valves. The NRC indicated in the EPG SER that while the BWR EPG's first direct the use of a vent path from the wetwell, thus benefitting from pool scrubbing, if wetwell venting capability does not exist, venting from the drywell is directed.

The benefits from drywell venting are less clear since release of fission products would occur earlier than if containment failure were allowed to occur or a higher venting setpoint were used.

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2.

Provide an assessment of the positive / negative implications of increasing the PCPL to a higher value.

Examples of factors that may be considered include, but are not limited to:

cost of modifications to any existing equipment a

consequences of a later release vice earlier release

=

likelihood of system recovery negating the need for venting increase in time for decay of fission products or site planning purposes 3.

The PCPL (44 psig) at FitzPatrick is close to the calculated pressure resulting from a design basis accident (39 psig).

Venting is not intended to be used for design basis accident conditions.

The EPGs direct venting as an anticipatory measure, directing venting prior to reaching the PCPL.

Provide the time span available for operators to initiate venting given the close proximity of the PCPL to DBA conditions.

Provide the time duration needed for operators to initiate venting.

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