ML20059E706

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Proposed Tech Specs LCO 3.5.D.4,clarifying ADS Operability Requirements
ML20059E706
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
ML20059E699 List:
References
NUDOCS 9401120176
Download: ML20059E706 (7)
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Text

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1 l Attachment I to JPN-93-086 1

I PROPOSED TECHNICAL SPECIFICATION CHANGES  ;

CLARIFICATION OF ADS OPERABILITY REQUIREMENTS :

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(JPTS-92-025) l I

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

9401120176 931228 E I PDR ADOCK 05000333 '

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JAFNPP 3.5 (cont'd) 4.5 (cont'd) during such time, the HPCI System is operable.

2. If the requirements of 3.5.D.1 cannot be met, the reactor 2. A logic system functional test. .

shall be placed in tha cold condition and pressure less 1 than 100 psig, within 24 hr. a. When it is determined that one valve of the ADS is i inoperable, the ADS subsystem actuation logic for the operable ADS valves and the HPCI subsystem shall be verified to be operable immediately and at

! least weekly thereafter.

b. When it is determined that more than one .!

relief / safety valve of the ADS is inoperable, the HPCI System shall be verified to be operable immediately.

3. Low power physics testing and reactor operator training shall be permitted with inoperable components as '

specified in 3.5.1.a and 3.5.1.b above, provided that reactor coolant temperature is _< 212*F and the reactor vessel is vented or reactor vessel head is removed.

4. The ADS is not required to be operable during hydrostatic pressure and leakage testing with reactor coolant i

l temperatures below 300*F and irradiated fuel in the reactor vessel provided all control rods are inserted.

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Amendment No. 33,448,4-79, 120

.- Attachmsnt ll to JPN-93-086 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGE CLARIFICATION OF ADS OPERABILITY REQUIREMENTS (JPTS-92-0251

1. DESCRIPTION OF THE PROPOSED CHANGE The proposed change to the James A. FitzPatrick Technical Specifications is addressed below.

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

Paoe 120. Soecification 3.5.D.4 Replace the phrase "between 212 *F and" with the word "below."

11. PURPOSE OF THE PROPOSED CHANGE This application for an Amendment to the James A. FitzPatrick Technical Specifications clarifies Limiting Condition for Operation (LCO) 3.5.D.4. Amendment 179 (References 1 and 2) added LCO 3.5.D.4 to permit hydrostatic and leakage testing at temperatures up to 300*F without requiring certain equipment, including  :

the automatic depressurization system (ADS), to be operable. However, LCO 3.5.D.4 ,

was interpreted to require the ADS be operable at temperatures less than 212*F.

Requiring the ADS to be operable during hydrostatic and leakage testing with temperatures below 212'F was clearly not the intent of Amendment 179. The proposed change will clarify LCO 3.5.D.4 to resolve this concern.

111. JAFETY IMPLICATIONS OF THE PROPOSED CHANGE The ADS is part of the reactor pressure relief system which has the safety objective of preventing overpressurization of the reactor coolant system (RCS). The ADS is also a major system of the Emergency Core Cooling System (ECCS). Following small breaks in the RCS boundary, the ADS rapidly depressurizes the RCS. This permits the core spray system or the low pressure coolant injection (LPCI) system to actuate.

The request for and issuance of Amendment 179 was intended to allow hydrostatic and leakage testing of the RCS boundary at temperatures up to 300*F without requiring certain safety related systems to be operable. This position was accepted by the NRC in its safety evaluation for Amendment 179 by acknowledging that:

"... the required hydrostatic pressure and inservice leak testing cannot be conducted without making HPCI, RCIC, ADS, and SRVs inoperable. The proposed changes to the TS will allow testing to be conducted at elevated temperatures with these systems inoperable."

However, LCO 3.5.D.4 as approved by Amendment 179 could be misinterpreted as requiring ADS to be operable during hydrostatic and leakage testing below 212*F,

  • Attachmsnt 11 to JPN-93-086 SAFETY EVALUATION Page 2 of 3 while exempting the operability requirement between 212*F and 300*F. This clarification of LCO 3.5.D.4 to allow hydrostatic and leakage testing below 300*F without requiring the ADS to be operable corrects the specification to read as originally intended.

The proposed change has no adverse safety implications. The change involves no modification of hardware, operations or procedures and will not alter the conclusions of the plants accident analyses as documented in the FSAR or the NRC staff SER.

The change is administrative in nature since it only clarifies the Technical Specifications as agreed to with the NRC in a prior amendment.

IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick 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 plant accident analyses are not affected by the proposed Technical Specification change. Prior to implementation of Amendment 179, hydrostatic and leakage testing of the RCS was performed with reactor coolant temperatures below 212*F while the ADS was inoperable. Amendment 179 revised the Technical Specifications in anticipation of increased pressure temperature limits requiring hydrostatic and leakage testing at or above 212*F. Requiring the ADS to be operable during hydrostatic or leakage testing with temperatures below 212*F was clearly not the intent of Amendment 179. The change will not increase the probability or consequences of previously evaluated accidents.

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

The proposed change involves no modifications to hardware, analyses, operations or procedures. The change clarifies LCO 3.5.D.4 to allow hydrostatic and leakage testing of the RCS below 300*F without requiring the ADS to be operable. The change is administrative in nature since it only clarifies the intent of the Technical Specifications as agreed to with the NRC and cannot create a new or different .

kind of accident.

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

The proposed change will not affect any plant safety margins. The existing plant accident analyses are not affected by the proposed change. This revision of LCO 3.5.D.4 is intended to clarify that the ADS is not required to be operable during hydrostatic or leakage testing of the RCS. This position is substantiated by the

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I Attachm:nt 11 to JPN-93-086 SAFETY EVALUATION  !

. Page 3 of 3 NRC safety evaluation for Amendment 179 which acknowledges that hydrostatic and leakage testing can not be performed without making the ADS, and other systems, inoperable.

V. IMPLEMENTATION OF THE PROPOSED CHANGE implementation of the proposed change will not affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the change impact the environment. The change will not result in any new releases to the environment since there are no hardware, structural, or operational changes. For these same reasons, the change poses no radiological or fire hazards. The change does not alter the goals or intent of  ;

the relevant LCO or associate Surveillance Requirement.

VI. CONCLUSION The change, as proposed, does not constitute an unreviewed safety question as l defined in 10 CFR 50.59. That is, it: j

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 l l

3. will not reduce the margin of safety as defined in the basis for any technical specification.

The change involves no significant hazards consideration, as defined in 10 CFR 50.92.

Vll. REFERENCES

1. NYPA letter, R.E. Beedle to NRC, dated January 9,1992, (JPN-92-002),

" Proposed Changes to the Technical Specifications Reactor Vessel Hydrostatic Testing."

2. NRC letter, B.C. McCabe to R.E. Beedle, dated March 9,1992, issuing Amendment 179 to the Technical Specifications.
3. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, Section 4.4 " Pressure Relief System," through Revision 5, dated January 1992.
4. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972, and Supplements.

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Attachment lit to JPN-93-086 PROPOSED TECHNICAL SPECIFICATION CHANGE

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l New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT ,

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