ML20058H199

Grants Temporary Waiver of Compliance W/Ts 3.7.D.2 & 3.7.D.3 Re Mod to Isolate Reactor Coolant Sample Line.Temporary Waiver Authorized Because solenoid-operated Containment Isolation Valve Safety Significance Low

ML20058H199
Person / Time
Site:	FitzPatrick
Issue date:	11/07/1990
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Fernandez W POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
NUDOCS 9011150010
Download: ML20058H199 (8)

Text

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NOV 071990 t i

, l Docket No. 50-333

\

New York Power Authority

. James A. FitzPatrick Nuclear Power Plant

' ATTN: Mr. William Fernandez Resident Manager j Post Office Box'41-Lycoming, New York 13093

-Gentlemen:

Subject:

Granting of Temporary Waiver of Compliance This letter- confirms the . November 2, 1990 oral. granting of your -

November 2,1990 request to waive compliance with portions of two sections of sTechnical Specification to allow continued operation while a minor modification is implemented' for isolation of ' a reactor coolant sample - line. . Technical l

' Specifications 3. 7.D.2' and 3.7,0.3, which require that a reactor shutdown- be l initiated -if an inoperableicontainment isolation valve cannot be repaired or  ;

. isolated within' 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s:were : partially -waived to' grant the above request; .the: '

Lwaiver was to expire at 6:00 p.m., November 6,1990. :We- have since learned 4

that the ' isolation of the ' reactor coolant. system sample line was- accomplished. 1 J

on: Saturday, November 3, .1990'. ; As such, the : effective period of the temporary; -l

waiver' was terminated at the time theiline was isolated. -1 L

iThe- temporary Lwaiver - of . compliance' was authorized because the safety )

. ,  ; significance associated with the leakage. from the solenoid operated containment- l isolation: valves in question (02-2SOV-39:and 02-2S0V-40), for the' period of-the-  ;

twaiver,t wasilow. Additionally, your. proposed compensatory actions, . including "

n i o' . closure and- removal -of power from ,the solenoid ' operated valves,- closure. of 1the l 3 manual Lvalves .at3he" sample sink- and in. the crack arrest' verification system provided( for .adeqJate - isolation' of the: containment < penetration: prior to the

, L repair, 'were D an acceptable means' of / minimizing ' the leakage ' through c this

containment penetration .while L actions Twere : to be taken ' to af feet isolation of the penetratior(cutting; and Lcapping : of ythe' sample :line). In particular, the.

leakage 7thrcygh theseDvalves"in thefevent; of' aniaccident. would constituteoa' R small portion of' the total Type B and6C penetrationJ allowable'. leakage. . 'If -

1 added to:the: current Type B'and C local leak rate total, penetration leakage is 1 still' 'substantially:~below' the allowed Technical Specification leak rate for

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Type B.and CLpenetrations1(0.6 La). '

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,MJ. g 0FFICIAL RECORD COPY'FITZPATRICK WAIVER - 0001.0.0 U' l 11/06/90 9011150010 901107 I 1

PDR ADOCK 05000333 \

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3 New York ~ Power Authority 2 NOV 0 71980 >

1 d copy-of your'-request is enclosed for reference.

Sincerely,

[ original signed by William F. Kane]

Thomas T. Martin Regional Administrator ,

En' closure:  :

As stated-l cc w/ enc 1

, J.:Phillip Bayne, President- i J. Brons,-Executive Vice President  !

A. :Klausmann, . Senior Vice President - Appraisal and Compliance Services i

'G.>Tasick, Quality Assurance Superintendent G..Wilverding, Manager Nuclear Safety Evaluation  !

'G..Golastein, Assistant General Counsel 6  !

R..Beedle, Vice President Nuclear Support l'

.S. Zu11a', Vice President Nuclear Engineering' .

W.- Josiger,;Vice President Nuclear Operations & Maintenance NH' EJ. Gray,: Director Nuclear' Licensing - BWR LDepartment:of Public Service, State of New-York- t L  : State of New York, Department _of/ Law

~Public Do'cument Room (PDR).

Local:Public Document Room (LPDR)

Nuclear Safety:Information Center (NSIC)  !

K.' Abraham;.PA0(2)- q NRC Resident. Inspector j

~ State of New York, SL0' Designee il

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OFFICIAL RECORD COPY FITZPATRICK WAIVER - 0002.0.0 11/06/90

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New York Power Authority 07 E .[

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Region-I Docket' Room (with concurrences)

R. Bellamy, DRSS

.W. Hehl, DRP J. Wiggins, DRP J.'Linville, DRP D.:Vito, DRP- >

'G. Meyer, DRP

.M. Miller, DRP  ;

J. Lieberman, OE i

- T. Murley, NRR J. Partlow, NRR '

.S.:Varga, NRR E. Greenman, NRR- >

4 'T; Mendiola. NRR ~

R. Capra, NRR D. LaBarge, NRR'

.J, Caldwell, EDO

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, RI:DRP GMeyer/mjd- 'RG lo L NRR-or'- r: Rifh RI:RA TMartin

@T $he 11/6 /90 11/ /90 -11/h/90 1 /90 11/6/90 11'/ /90 0FFICIAL RECORD COPY FITZPATRICK WAIVER - 0003.0.0 11/06/90

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ENCLOSURE ,

.' NEW YORK POWER At1THORITY _ _

. JAMES A.,FITZPATRICK NUCLEAR POWER PLANT Request for Waiver of comeliance 4

1. A Discussion of Requirements for Which a Waiver is Request'ed The Authority requests a waiver of compliance from two sections in the FitzPatrick Technical Specifications:

3.7 D.2 and 3.7.D.3.

Technica1' specification section 3.7.D.2 states:

"With one or more of the isolation valves listed in Table 3.7-1 inoperable, maintain at least one-isolation valve operable in each affected penetration that-is open and:

, a.- Restore the inoperable valve (s) to operable status within 4' hours; b;- Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least on deactivated automatic valve secured in the closed position. Isolation valves closed to

' satisfy these requirements may be reopened on an

. intermittent basis under administrative control; or

c. fIsolation each affected penetration within,4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use.of at;1 east one closed manual valve or a blind flange."

Technical-Specification Section 3.7.D.3 states:

T

'"If Specifications'3.7'.D.1 or 3.7.D.2 cannot be met,'an.

, orderly' shutdown shall be'inititted:and the reactor shall be e , ,in cold condition within1241 hours."

2? ASDisc~uAsionofCircumstances.Surroundingthe: Situation- .

Include the Need for Prompt' Action- .

Routine inserviceitests have legd.to the. discovery-of higher than anticipated leak rates through'two containment F = isolation valves (02-2SOV-39 and 40): on the Reactor Coolant .

Sample System. The line is equipped with.two solenoid

. operated containment isolation valves, one inside and one outside.

In excess flow check valve is. located .inside this -line outside the' outboard containment isolation valve. The line can be isolated'using man'ually operated " hand" valves at the sample sink and the crack arrest verification system. -

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j' NEW YORK POWER AUTHORITY *

.. JAMES A.-FITZPATRICK NUCLEAR POWER PLANT i Recuest for Waiver of Como11ance

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With both valves indicating closed,-leakage has been estimated to be between 1.2-and 1.5. liters-per minute. This leak rate exceeds the leakage critaria of ASME Section XI ,

for the specific containment isolation valves,.and therefore )

re@ ires that the Authority declare these valves inoperable.

This declaration, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. in turn, would require plant shutdown '

For the reasons detailed in Section 4 below, the Authority doms not consider this a significant safety concern. i F shutting the plant down to repair or rectify the problem ,

constitutes Au thority. a unnecessary financial hardship on the

3. A-Discussion of Compensatory Actions Both 02-2SOV-39 position.- and 40-will be maintained in the closed I

.The manual valves at the sample sink and the crack arrest verification system will also be kept in the  ! .

closed position except for,short periods of time. required to-  !

support the repair method described later except for small periods of time required to support the capping evolution.- l 4.

A Proliminary Evaluation of the Safety Significance and Potential Consequences of the Proposed Request '

Since the potential offsite exposure resulting from this condition is similar toithat associated withiinstrument o

-lines: penetrating primary containment;.the_ potential offsite'

- exposure will be substantially;below the-guidelines of.

10CFR100. ~If weLaddithis new leakage-(293 SCFD) into,the  !

e+y running (1417.70 totaliof the typesB and C local leak rate,resultL SCFD), this is still substantially:below 3216'SCFD

.which is=0.6.La.

H General Design, Criteria 55 and 56 require that1each line that penetrates primary reactor containment and is part of 4

' Lthe reactor coolant pressure boundary or that is connected -

directly to.the containment atmosphere have one automatic valve outside containment a unless it can be demonstrated ,

that the design is acceptable on some other defined basis".

'NRC' Safety Guide 11, " Instrument Linet Penetrating Primar .

%; Reactor Containment" dated March 10,: 1971'is that basis. y Safety Guide 11 permits self-actuated excess flow check valves to satisfy GDC 55 and 56-for instrument liens {'

(Section~B,. Discussion). '

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07 IhF@. FR 51534M654 F3 NEW YORK POWER AUTHORITY I JAMES A. FITZPATRICK NUCLEAR POWER PLANT - -

Recruest for Waiver of come11ance Section C.l.b.of Safety Guide 11 specifies that-these lines  !

contain orifices sized to assure that in the event of a

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postulated failure of the piping in the line outside primary i containment during normal operating,  !

(1) the leakage is reduced to the maximum extent practical consistent with other safety requirements, (2) the rate and extent of coolant loss are within the capability of the reactor coolant makeup system, (3) che' integrity and functional performance of secondary containment, if:provided, and associated safety systems (e.g. filters, standby gas treatment system) be maintained,.and (4) the potential offaite exposures will be substantially below the guidelines of 10CFR100. i In this situation, each of these four conditions is i

satisfied.by the physical condition. The two " leaky" closed

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containment, isolation valves -(02-2SCV-39 and 40) -function as

.a very restrictive orifice.

(Whilelthe'GDC were nor. formally promulgated by-the NRC -

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untillafter the FitzPatrick Construction Permit was issued, a supplement to SG 11 suggests that plants met the guide.

Regardless of the-applicability offthe GDC to FitzPatrick, J

.the: technical basis.for the acceptability of flow

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'restrictors in small diameter lines-is valid.)

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- Section ' 4. 8"of" ANSI' 56'. 2/ ANSI N271- 1976, , "American National Standard Containment. Isolation Provisions for Fluid' Systems"  !

(approved June 28, 1976)L L also ref are to -SG 11 for ' suit *ble "

criteria for isolation: provisions on' instrument liens-penetrating primary containment. NRC Standard Review-Plan

'Section 6.2.4, Rev. 2, July 1981', " Containment Isolation, a

System" makes a similar reference to-the SG,

.Technica14snecifications E' Bases. 4.7 - (p.197)L of the FitzPatrick Technical Specifications also> acknowledges the acceptability of orifices'~in small diameter lines.

"The primary containment is penetrated by several small '

diameter instrument lines connected to the reactor >

coolant system.. Each instrument line contains a 0.25 in. restricting. orifice inside primary containment and an excess flow check valve outside primary l containment."

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JAMES A.sFITZPATRICK NUCLEAR POWER PLANT secuest for Waiver of comeliance L. A Discussion Which Justified the Duration.of the Request The waiver should-remain in effect until a minor modification can be completed which will " cut-and-cap" the

' sample line. The Authority estimates that although the.

actual ~ modification can be completed in a single shift

, hours), 3 days are necessary to prepare,-review, approve (8 and 7

qualify the procedure and safety evaluation associated'with

, the; modification. Therefore, the waiver should have a

. 14 duration of at least 4: days (96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />) form time of issuance.

6. - The Basis for the Conclusion That the Request Does Not Involve a Significant Hazards Conclusion operation of the-James A. FitzPatrick Nuclear Power Plant in G

the presenticircumstances would not involve a significant

' hazards considerati6n as defined in 10CFR50.92, since it would not:

involve a significant increase in the probability or

consequences of an

accident previously; evaluated. The

' > valves?in question are primary containment: isolation

. valves.and ware designed and installedito mitigate the consequences of a: design basis-accident. 'The1 valves

-close andilsolate the reactor recirculaticn systen in the;eventJof a design; basis accident. 4 Theivalves:have-been" secured'in the closed position and will; remain

" - closed.; In addition,_they_are-bothist111'capab1'e'of

' closure in response to a containment; isolation signal.

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YAisl'ight{ increase.in theivalvel leik rate?cannot

, increase the probability'of aLdesign basis: accident.'

u- The increased leak rate throughithe valves also will not result in a significant: increase:in the consequens m of an accident since the1 increase in

~ leakage is.< mall.- With both-valves shut, the leak. rate is approximately 1.2 liters per' minute at.a reactor g operating pressure of 1005gpsig. 'Following a_ design basis accidenti reactor pressure vould be1substantially.

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'  : lower resulting in'an even lower leak rate. Even if'a

_ design' basis accident were to- occur, g and the valves' 11eaked-at their.present rate,'the consequences <would be

,' within theLbounds of previously evaluated accidents.

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' NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT Reeruant far Waiver af camm11ames craata the possibility of a new or different kind of accident from those previously evaluated. As stated above, these valves function to mitigate the consequences of a design basis accident. The slight increase in leak rate through the valves cannot create a new or different kind of accident since isolation valve leakage was previously postulated and evaluated.

involve a significant reduction in the margin of safety. As stated above, the increased leak rate has no consequences unless a design basis accident occurs.

Even in the extremely unlikely event that one occurs, the increased consequences are.still within the bounds of previously evaluated accidents. Therefore, there is  ;

no decrease *in the margin of safety. i

7. The Basis for the Conclusion that the Request Does Not  !

Involve Irreversible Environmental Effects i

Neither this waiver nor the planned modification is expected to have any irreversible environmental effects. The

' increased leak rate has no aonsequences at all unless a design basis accident occurs. Even in this unlikely. event and assuming that all leakage through the valves bypasses ,

the standby Gas Treatment System and reaches the environment,-there would still be no significant or i

, irreversible environmental consequence. i L

PORC Meeting: 90-102_ Date: 11/02/90 i

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