ML20059C970

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Proposed Tech Specs Revising Scope of Startup & Power Escalation Repts to Reflect Guidance Provided in STS, NUREG-1433
ML20059C970
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 12/28/1993
From:
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20059C955 List:
References
RTR-NUREG-1433 NUDOCS 9401060279
Download: ML20059C970 (8)
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Attachment I to JPN-93-085 PROPOSED TECHNICAL SPECIFICATION CHANGES.

REVISED SCOPE FOR PLANT STARTUP AND POWER ESCALATION REPORTS (JPTS-91-002) l I

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New York Power Authority J

JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 Attachment til to JPN-93-085 9401060279 931228 W

PDR ADOCK 05000333 Tf P

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JAFNPP 2.

the change is approved by two members of the plant management staff, at least one of whom holds E hnior Reactor Operatcr's license on the unit affected.

3.

The change is documented, reviewed by the PORC and approved by the Resident Manager within 14 days of implementation.

6.9 REPORTING REQUIREMENTS (A) ROUTINE REPORTS The following reports shall be submitted in accordance with 10 CFR 50 unless otherwise noted.

1.

STARTUP REPORT a.

A summary report of plant startup and power escalation testing shall be submitted following (1) amendment to the license involving a planned increase in power level, (2) installation of fuel that has a different duign or has been :nanufactured by a different fuel supplier, and (3) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. The Startup Report for the initial fuel cycle shall address each of the tests identified in the FSAR and shallinclude a description of the measured values of the i

operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other commitments shall be included in this report. Startup Reports for subsequent fuel cycles shall address startup tests that are necessary to demonstrate the acceptability of changes and modifications.

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Amendment No. 7,22,32,'10, l

254a

' 1 to JPN-93-085 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REVISED SCOPE FOR PLANT STARTUP AND POWER ESCALATION REPORTS (JPTS-91-002) 1.

DESCRIPTION OF THE PROPOSED CHANGES The proposed changes to the James A. FitzPatrick Technical Specifications are i

detailed below.

Minor changes in format, such as type font, margins or hyphenation, are not described in this submittal. These changes are typographical in nature and do not affect the content of the Technical Specifications.

Paae 254-a Soecification 6.9.A I

i Replace the paragraph:

"In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Director of the Regional Office of Inspection and Enforcement unless otherwise noted" with "The following reports shall be submitted in accordance with 10 CFR 50 unless otherwise noted."

s Paae 254-a Soecification 6.9. A.1.a in the second sentence of this specification, replace the word " report" with the phrase "Startup Report for the initial fuel cycle."

At the end of the specification add the following sentence:

"Startup Reports for subsequent fuel cycles shall address startup tests that are necessary to demonstrate the acceptability of changes and rnodifications."

Replace page number "254-a" with "254a."

Attichm:nt 11 to JPN-93-085 SAFETY EVALUATION Page 2 of 4 II.

PURPOSE OF THE PROPOSED CHANGES l

This proposed technical specification amendment updates the title of the NRC i

recipient of plant startup reports and revises the scope of startup and power i

escalation reports to reflect the guidance provided by the Standard Technical Specifications (STS) (Reference 1). Current Technical Specification requirements j

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"... report shall addtcss each of the tests identified in the FSAR..."

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The list of tests provided in the FSAR (Reference 2) includes many tests which were required for the initial plant startup but are not performed for subsequent startups.

The two reasons for not performing a specific test were either:

a) performance e' a particular test would challenge the reactor protection and safety systeia ad/or place the plant in a degraded condition, or b) the test is no longer required because it was originally performed to establish or verify a plant parameter prior to the plant having an operating history.

Current FitzPatrick practice (References 3 and 4) in accordance with Technical Specification requireinents address the unperformed tests in a section of the startup report by identifying the test,its purpose, and the reason for not performing the test.

In reviewing the STS and its approach to addressing startup test requirements the Power Authority has concluded that the inclusion of such a section in the startup reports is not useful or necessary. This submittal, therefore, revises the Technical Specifications to permit subsequent startup reports to address only those tests that are actually performed in support of plant startup/ power escalation.

Ill.

SAFETY IMPLICATIONS OF THE PROPOSED CHANGES The proposed changes to the Technical Specifications have no adverse safety implications. These changes are consistent with and reflect the guidance provided by the STS in allowing startup reports, other than the initial startup report, to "...

address startup tests that are necessary..."

The resulting removal of tests, that are not performed, from the startup test report will not alter those plant parameters that are actually tested. These changes will also have no effect on existing test procedures or methodologies.. The proposed technical specification changes do not involve any physical modification o' plant systems, components, or structures. The removal of this extra startup report text will not alter the plant operator's ability in initiating and establishing a controlled plant startup.

The revised startup report requirements will not place FitzPatrick in a position of noncompliance with regulatory criteria nor alter the conclusions of the plant's accident analyses as documented in the FSAR or the NRC staff SER.

Att:chmtnt ll to JPN-93-085 SAFETY EVALUATION Page 3 of 4 IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatricf plant in accordance with the proposed Amendment would not involve a significant hazards consideration as defined 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 changes involve no hardware modifications, no changes to the operation of any system or component, no changes to structures, and alters future startup reports by addressing only tests that are performed. A change in reporting format will not eliminate the performance of startup tests that are necessary or required. These changes can not alter the probability or consequences of existing accident analyses as documented in the FSAR or the NRC staff SER.

2. create the possibility of a new or different kind of accident from those previously evaluated.

The changes do not alter the testing p.'ocedures or methodologies. The changes provide a basis, in accordance with NRC guidance, for allowing future startup test reports to mention and discuss only those tests that are actually performed.

These changes can not rcipit in a new or different type of accident than those previously evaluated.

3. involve a significant reduction in the margin of safety.

There are no changes to tests that are performed in support of plant startup l

(Reference 5). Removing a requirement for reporting on tests that are not performed will not cause a reduction in any margin of safety.

V.

IMPLEMENTATION OF THE PROPOSED CHANGES These changes improve the consistency between the Technical Specifications and the STS. Implementation of these changes will not affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will they impact the environment.

Attachm:nt 11 to JPN-93-085 SAFETY EVALUATION

- Page 4 of 4 VI. CONCLUSION The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they:

1. will not increase the probability nor the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report:
2. will not create the possibility of an accident or malfunction of a type different from any previously evaluated in the Safety Analysis Report; and
3. will not reduce the margin of safety as defined in the basis for any technical spec;fication.

The changes involve no significant hazards consideration, as defined in 10 CFR 50.92.

Vll. REFERENCES l

1. NRC NUREG-1433 " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/4)," Revision 0, dated September 1992.
2. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, Sections 13.7 " Reactor Startup and Power Test Program" and 13.9.6

" Administrative Records and Reports," through Revision 5, dated January 1992.

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3. NYPA letter, W. Fernandez to NRC, dated September 17,1990 (JAFP 90-0697),

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" Transmitting the Cycle 10 Start-up Testing Report."-

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4. NYPA letter, H.P. Salmon, Jr. to NRC, dated April 2,1993 (JAFP-93-0182),

" Transmitting the Cycle 11 Start-up Testing Report."

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5. James A. FitzPatrick Reactor Analyst Procedure RAP-7.3.30 " Cycle Startup Reactor Physics Test Program," Revision 3, dated September 11,1992.
6. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated l

November 20,1972, and Supplements.

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PROPOSED TECHNICAL SPECIFICATION CHANGES -

REVISED SCOPE FOR PLANT STARTUP.

AND POWER ESCALATION REPORTS MARKUP OF TECHNICAL SPECIFICATION PAGES (JPTS-91-002) -

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f New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59

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'-3r The change ~is-documented, reviewed by the PORC and approved by the-l Resident Manager within 14 days of implementation.

j 6.9 REPORTING REOUIREMINTS (A) ROUTINE REPORTS l

O Mstion to the applicable reporting _raquir-==nts of Title 162 IM &:r"f!

icoda nf Fadarmi naculations,{fhe following reports shall be submittedJtntheDicaeto.roftheRegionalOfficeofInspectionang y @ orSamaal/unless otherfise noted.

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1. STARTUP REPORT l

A summary report of plant startup and power escalation a.

testing shall be submitted following (1) amendment to the license involving a planned increase in power level. (2) l installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (3) i ##[

  • l modifications that may have significantly altered the s+d 4 nuclear, thermal, or hydraulic performance of the plant.

l L,Wg h *hy.{ C,. 4 TheTsepeet shall address each of the tests identified in the l

'd-FSAR and shall include a description of the measured values C

of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective l

actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other commitments l

shall be included in this report.4-mse t=ti Smig Rys G subge,d Sel cycles sk$ acl ben M

tes'f5 Tbei ctce necesm.

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Amendment No..P, M. x,110 25

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