Text

Proposed Tech Specs Revising Primary Containment Atomsphere Monitoring Requirements
	ML20071P611
Person / Time
Site:	FitzPatrick
Issue date:	08/04/1994
From:	; POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	;
Shared Package
ML20071P601	List: JPN-94-038, Forwards Application for Amends to License DPR-59,proposing Ts,To Revising Primary Containment Atomsphere Monitoring Requirements; ML20071P603; ML20071P611;
References
	NUDOCS 9408090438
	Download: ML20071P611 (24)
	v • d • e

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4 3.2 (cont'd) 4.2 (cont'd) -

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'E E. Drvwell Leak Detection E. Drvwell Leak Detection

> Instrumentation shall be calibrated and checked as indicated in Ro The limiting conditions of operation for the instrumentation that M"

n monitors drywell leak detection are given in Table 3.2-5. Table 4.2-5.

0* F. F. (Deleted)

(Deleted)

G. Recirculation Pumo Trio G. Recirculation Pumo Trio S@oo LU The limiting conditions for operation for the instrumentation that Instrumentation shall be functionally tested and calibrated as p trip (s) the recirculation pumps as a means of limiting the ' indicated in Table 4.2-7.

consequences of a f ailure to scram during an anticipated transient are given in Table 3.2-7. System logic shall be functionally tested as indicated in Table 4.2-7.

H. Accident Monitorina Instrumentation H. Accident Monitorina Instrumentation The limiting conditions for operation of the instrumentation that provides accident monitoring are given in Table 3.2-8. Instrumentation shall be demonstrated operable by performance of a channel check, channel calibration and functional test as

1. 4kv Emeroency Bus Undervoltaae Trio indicated in Table 4.2-8, as applicable.

The limiting conditions for operation for the instrumentation that prevents damage to electrical equipment or circuits as a result of either a degraded or loss-of-voltage condition on the emergency electrical buses are given in Table 3.2-2.

i Amendment No. JD0;J:MTlJ&r,j,9tM 54

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TABLE 3.2-8 ACCIDENT MONITORING INSTRUME!NTATION No. of Channels Minimum No. of Mode in Which Provided by Operable Channels Instrument Must Instrument - Design Required be Operable Action

8. Torus Water Level (wide range) 2 1 Note J Note A 23Ll-202A or 23LR-202A/203A

, 23LI-202B or 23LR-202B/203B 4

9. Torus Bulk Water Temprature 2 1 Note J Note A '

(16-1TI-131 A or 1c r.-131 A)

(16-1TI-131B or '6 . A-1318)

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10. Torus Pressure 2 1 Note J Note A (27PR-101 A) ,

(27PR-10181)

11. Primary Containment Hydrogen / Oxygen 2 1 Note J, K Note F l

Concentration 27PCR-101 A 27PCR-101B

12. Reactor Vessel Pressure 2 1 Note J Note A 06PI-61 A or 06PR-61 A 06PI-61B or 06PR-61B

13. Reactor Water Level (fuel zone) 2 1 Note J Note A (02-3Li-091)

(02-3LR-098)

14. Reactor Water Level (wide range) 2 1 Note J Note A 02-3LI-85A) 02-3LR-85B)

Amendment No.1)&,'y 77b

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TABLE 3.2-8 (Cont'd)

ACCIDENT MONITORING INSTRUMENTATION NOTES FOR TABLE 3.2-8 A. With the number of operable channels less than the required minimum, either restore th.3 inoperable channels to operable status within 30 days, or bo in a co!d condition within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

B. With the number of OPERABLE channels less than required by the minimum channels OPERABLE requirements, initiate an alternate method of monitoring the appropriate parameter (s) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and: (1) either restore the inoperable channel (s) to OPERABLE status within 7 days of the event, or (2) prepare and submit a Special Report to the Commission within 14 days following the event outlining the cause of the inoperability, the action taken, and the plans and schedule for restoring the system to OPERABLE status.

C. Each Safety / Relief Valve is equipped with two acoustical detectors, one of which is in service. Each SRV also has a backup thermocouple detector. In the event that a thermocouple is inoperable, SRV performance shall be monitored daily with the associated in service acoustical detector.

D. From and after the date that both of the acoustical detectors are inoperable, continued operation is permissible until the next outage in which a primary containment entry is made provided that the thermocouple is operable. Both acoustical detectors shall be made operable prior to restart.

E. In the event that both primary (acoustical detectors) and secondary (thermocouple) indications of this parameter for any one valve are disabled and neither indication can be restored in forty-eight (48) hours, the reactor shall be in a Hot Shutdown condition within twelve (12) hours and in a Cold Shutdown within the next twenty-four (24) hours.

F. With the number of operable channels less than the required minimum, continued reactor operation is permissible for the following 30 days provided at least once each 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , either the appropriate parameter (s) is monitored and logged using 27PCX-101 A, B, or an appropriate grab sample is obtained and analyzed. If this condition can not be met, be in the Wt Shutdown mode within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

G. This parameter and associated instrumentation are not part of post-accident monitoring.

H. This instrument shall be operable in the Run, Startup/ Hot Standby, and Hot Shutdown modes.

J. This instrument shall be operable in the Run and Startup/ Hot Standby modes.

K. Primary containment atmosphere shall be continuously monitored for hydrogen and oxygen when in the Run and Startup/ Hot Standby modes, except when the Post-Accident Sampling System (PASS) is to be operated. When the PASS is to be operated, the containment atmosphere monitoring systems may be isolated for a period not to exceed 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months in a 24-hour period.

Amendment No. jM,J9f, 77d

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TABLE 4.2-8 MINIMUM TEST AND CAllBRATION FREQUENCY FOR ACCIDENT MONITORING INSTRUMEN T ATION Instrument instrument Instrument Functional Test Calibration Frequency Check

1. Stack High Range Effluent Monitor Once/ Operating Cycle Once/ Operating Cycle Once/ day

2. _ Turbine Building Vent High Range Effluent Monitor Once/ Operating Cycle Once/ Operating Cycle Once/ day

3. Radwaste Building Vent High Range Effluent Monitor Once/ Operating Cycle Once/ Operating Cycle Once/ day

4. Containment High Range Radiation Monitor Once/ Operating Cycle Once/ Operating Cycle Once/ day

5. Drywell Pressure (narrow range) N/A Once/ Operating Cycle Once/ day

6. Drywell Pressure (wide range) N/A Once/ Operating Cycle Once/ day

7. Drywell Temperature N/A_ Once/ Operating Cycle Once/ day

8. Torus Water Level (wide range) N/A Once/ Operating Cycle - Once/ day

9. Torus Bulk Water Temperature N/A Once/ Operating Cycle Oncelday

10. Torus Pressure N/A Once/ Operating Cycle Once/ day Primary Containment Hydrogen / Oxygen Concentration N/A Once/3 months Once/ day l 11. Analyzer

12. Reactor Vessel Pressure N/A Once/ Operating Cycle Once/ day

13. Reactor Water Level (fuel zone) N/A Once/ Operating Cycle Once/ day

14. Reactor Water Level (wide range) N/A Once/ Operating Cycle Once/ day Amendment No. pf 372,Jef, 86

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3.7 (cont'd) 4.7 (cont'd)

6. Oxygen Concentration 6. Oxygen Concentration

a. Primary containment oxygen concentration shall be- a. The primary containment oxygen concentration shall [

less than four volume percent within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of be verified to be within limits once each week. I exceeding 15% of rated thermal power during Instrument surveillances shall be performed as startup. specified in Table 4.2-8.

b. De-inerting may commence up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermal power to less than 15% of rated before a plant shutdown.

7. Drywell-Torus Differential Pressure 7. Drywell-Torus Differential Pressure

a. Differential pressure between the drywell and torus a. The pressure differential between the drywell and torus [

shall be maintained at equal to or greater than 1.7 shall be verified to be within limits once each shift. I psid except as specified in (1) and (2) below: Instrument surveillances shall be performed as specified in Table 4.2-8.

Amendment No. JC J8f, 180

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3.7 (Cont'd) 4.7 (Cont'd)

(1) The drywell to torus differential pressure shall be established within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 15%

rated thermal power during startup. The differential pressure may be reduced to less than the limit up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermal .

. power to less than 15% of rated before a plant shutdown.

(2) The differential pressure may be decreased to less than 1.7 psid for a maximum of four (4) hours during required operability testing of the HPCI, RCIC, and Suppression Chamber -

Drywell Vacuum Breaker System.

4 (3) If 3.7.A.7.a above cannot be met, restore the differential pressure to within limits within eight hours or reduce thermal power to less than 15%

of rated within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

j 8. If the specifications of 3.7.A.1 through 3.7.A.5 cannot be 8. Not applicable.

met the reactor shall be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Amendment No. )R397, 180a

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3.7 (cont'd) 4.7 (cont'd) ,

'!i B. Standbv Gas Treatment System B. Standbv Gas Treatment System !

1. Except as specified in 3.7.B.2 below both circuits of the 1. Standby Gas Treatment System surveillance shall be Standby Gas Treatment System shall be operable at all performed as indicated below:

times when secondary containment integrity is required.

a At least once per operating cycle, it shall be demonstrated that:

(1) Pressure drop across the combined high-efficiency and charcoal filters is less than 5.7 in. of water at 6,000 scfm, and ;

(2) Each 39kW heater shall dissipate greater than l 29kW of electric power as calculated by the following expression:

P = {JEI I

where:

P= Dissipated Electrical Power; E= Measured line-to-line voltage in volts (RMS); !

. i= Average measured phase current in amperes (RMS).

Amendment No.1ZJE,)8',fd(p0'KJK .19C 181

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ATTACHMENT 11 to JPN-94-038 Safety Evaluation Regarding Proposed Changes to Technical Specifications Primary Containment Atmosohere Monitorina (JPTS-93-010)

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

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Attachment il to JPN-94-038 -

SAFETY EVALUATION Page 1 of 7 i

1. DESCRIPTION OF THE PROPOSED CHANGES I

1 This application for an amendment to the James A. FitzPatrick Technical Specifications I

revises the primary containment atmosphere monitoring requirements. The specific j'

changes are as follow:

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1. Page 54, Specification 4.2.H, " Accident Monitoring Instrumentation," add the words )

i " functional test" to the list of tests performed and add the words "as applicable" at the .

I end of the sentence. The revised specification reads:

i i "H. Accident Monitoring Instrumentation ;

i i l Instrumentation shall be demonstrated operable by performance of a .

l l channel clieck, channel calibration and functional test as indicated in Table l 4.2-8,' as applicable."

2. Page 77b, Table 3.2-8, Item 11, change "drywell" to " primary containment."

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j Add a new note "K" to the primary containment hydrogen / oxygen monitoring :

1-instrumentation under the " Modes in Which Instrumentation Must be Operable" column. :

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3. Page 77d, revise Note F to read: )

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"F. With the number of operable channels less than the required minimum,

continued reactor operation is permissible for the following 30 days provided at least once each 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , either the apnropriate parameter (s) is

{

monitored and logged using 27PCX-101 A, B, or an appropriate grab sample j is obtained and analyzed. If this condition can not be met, be in the Hot j Shutdown mode within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ."

i Add a new note "K" to read:

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"K. Primary containment atmosphere shall be continuously monitored for ;

l' hydrogen and oxygen when in the Run and Startup/ Hot Standby l l modes, except when the Post-Accident Sampling System (PASS) is j i- to be operated. When .the PASS is to be operated, the containment l atmosphere monitoring systems may be isolated for a period not to exceed 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months in a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period."

4. Page 86, Ttt. 12-8, "Ifimum Test and Calibration for Accident Monitoring Instrumentatidil," Item 11, change "drywell" to " primary containment."

5. Page 180, revise Specification 3.7.A.6, " Oxygen Concentration" to read:

i "6. Oxygen Concentration

, ~ Attachment 11 to JPN-94-038 i SAFETY EVALUATION j Page 2 of 7 i

a. Primary containment oxygen concentration shall be less than four volume percent within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 15% of rated thermal power during startup.

b. De-inerting may commence up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing i thermal power to less than 15% of rated before a plant shutdown."

Revise Specification 4.7.A.6.a to read:

"The primary containment oxygen concentration shall be verified to be within limits once each weel: Instrument surveillances shall be performed as j specified in Table 4.2-8." _

Revise Specification 4.7.A.7.a to read:

"The pressure differential between the drywell and torus shall be verified to be within limits once each shift. Instrument surveillances shall be performed as specified in Table 4.2-8." l 1

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6. Page 180a, revise Specification 3.7.A.7.a.(1) to read:

"The drywell to torus differential pressure shall be established within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 15% rated thermal power during startup. The i differential pressure may be reduced to less than the limit up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months i prior to reducing thermal power to less than 15% of rated before a plant !

shutdown."

Revise Specification 3.7.A.7.a.(3) to read:

"If 3.7.A.7.a above cannot be met, restore the differential pressure to within limits within eight hours or reduce thermal power to less than 15% of rated within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ."

Revise Specification 3.7.A.8 to read:

"If the specifications of 3.7.A.1 through 3.7.A.5 cannot be met the reactor shall be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ."

7. Page 181, delete Specifications 3.7.A.9 and 4.7.A.9 in their entirety.

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Attachment ll to JPN-94 038 4 SAFETY EVALUATION Page 3 of 7 l

3 II. EIEPOSE OF THE PROPOSED CHANGES i

{ The purpose of the proposed changes is to consolidate the primary containment l atmosphere monitoring requirements of Specification 3.7.A.9 into Table 3.2-8,

" Accident Monitoring instrumentation." In addition, the proposed changes adopt

Standard Technical Specifications (STS) primary containment inerting and de-inerting

requirements and drywell to torus differential pressure monitoring requirements.

l lil. SAFETY IMPLICATION OF THE PROPOSED CHANGES i

i During normal operation and following a design basis accident (i.e., LOCA) the primary !

containment atmosphere needs to be inerted to ensure that hydrogen combustion 1 could not occur. Inerting is achieved by purging the primary containment with nitrogen i until oxygen concentration is less than four percent by volume. Nitrogen is also used to maintain the drywell to torus differential pressure at greater than or equal to 1.7 psig. This differential pressure is necessary to reduce water slug forces on the torus

and jet force on the downcomer pipe that could result during a LOCA.

1 When the primary containment atmosphere is inerted, operators cannot access the i

, containment to perform required surveillances and leak inspections unless they wear i self contained breathing apparatus. Technical Specification 3.7.A.6 allows for a 24 j hour time grace period following startup or before shutdown in which the primary

containment does not have to be inerted. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable

amount of time for plant personnel to perform required leak inspections and then to complete inerting or shutdown evolutions. The current reference condition for this 24 i hour " window" is when the mode switch is placed in the run position.

4 The proposed changes revise Specification 3.7.A.6 by adopting inerting and de inerting requirements which are consistent with the guidance of the STS (Reference 1). The

STS uses as the reference condition for inerting and de-inerting 15% rated thermal power instead of being in run mode. The proposed changes will require inerting to l; less than 4% O2concentration within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 15% rated thermal power i during startup and allow de-inerting 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermal power to less than 15% of rated before a plant shutdown. The basis for this change, as stated in the STS, is that at less than 15% rated thermal power and within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following startup there is a low probability that an event generating significant amount

, of hydrogen would occur. In addition, there is also a low probability that such an event

_ would happen within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before reaching 15% rated thermal power during

a shutdown.

Making the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " window" contingent upon core thermal power will allow to place the mode switch in run sooner, removing startup neutron monitoring instrumentation scrams (i.e., APRM 15% and IRM upscale /inop). This reduces the probability of spurious trips due to spiking of this instrumentation. In addition the proposed changes

l Attachment il to JPN-94-038 '

SAFETY EVALUATION Page 4 of 7 i

l will allow additional time to perform work / inspections in the drywell such as MSIV testing, MSIV_ limit switches adjustments, MOV testing, leak inepection, before the l containment is inerted. Therefore, implementing thase changes will increase overall plant reliability and capacity factor, j This proposed change does not affect the assumptions or, conclusions contained in the plant safety analyses. The proposed change does not involve physical modification to j the plant nor involve any accident initiators. Therefore, the probability of an accident ;

occurring remains unchanged. Accident analyses contained in FSAR Chapter 14. J (Reference 2) assume that a LOCA occurs from full power. The consequences of a LOCA below 15% rated thermal power would be less severe and would produce less -

hydrogen. The containment is designed to accommodate a much larger amount of ;

hydrogen and heat.

l Consistent with this proposed change, Specification 3.7.A.7.a.(1) is being revised to i roquire establishing drywell to torus differential pressure within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding ;

15% rated thermal power during startup. The differential pressure can be reduced to-less than the established limit up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermal power to less ,

than 15% of rated before a plant shutdown. _ Specification 3.7.A.7.a.(3) is being revised to allow eight hours to restore the differential pressure to within limits or to reduce thermal power to less than 15% of rated within the next twelve hours. These proposed :

changes are consistent with the STS guidance which require the same plant conditions for applicability of primary containment oxygen concentration limiting conditions for ,

operation as for the drywell to torus differential pressure. As stated in the STS, the completion times for the proposed actions are reasonable based on industry operating experience.

Specification 3.7.A.8 is being changed to indicate that 3.7.A.6, as revised, does not require shutdown to the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ,

Changes are also proposed to surveillance requirements 4.7.A.6.a, " Oxygen l Concentration," and 4.7.A.7.a, "Drywell Torus Differential Pressure." These two !

specifications currently refer to Table 4.2-8 tor the instrument surveillances but do not I specify surveillance frequency for the monitoring parameters. To clarify that these requirements are different, the proposed change will revise Specifications 4.7.A.6.a and 4.7.A.7.a to indicate the specific surveillance frequency for the primary containment oxygen concentration and the drywell to torus differential pressure. The primary containment oxygen concentration will be verified to be within limits once each week consistent with STS guidance. The drywell to torus differential pressure will be verified I to be within limits once each shift consistent with current plant practice.

Several administrative changes are proposed to Tables 3.2-8, " Accident Monitoring Instrumentation," and 4.2-8, " Minimum Test and Calibration Frequency for Accident Monitoring Instrumentation." One of the changes revises item 11 to refer to " primary containment" instead of "drywell" hydrogen / oxygen concentration. This change clarifies

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Attachment ll to JPN-94-038 i SAFETY EVALUATION Page 5 of 7 i

that the monitoring instrumentation senses both the drywell and torus atmospheres not i just the drywell. This term is also used in the proposed Note K to this table and in the STS.

l l i The proposed change also affects Table 3.2-8 by revising Note F and by adding e new l

. Note K. Currently, Note r instructs the plant operators to refer to Specification 3.7.A.9 !

if minimum hydrogen / oxygen n'onitoring is not met. The proposed change eliminates l the reference to Specif cation 5.7.A.9 by moving the action statement for l hydrogen / oxygen concentration from Specifications 3.7.A.9.a and 3.7.A.9.b to Table l 3.2-8, Note F. The proposed action statement is also revised such that if recorder

] 27PCR-101 A or B is inoperable, a daily monitoring and logging of the appropriate 1 i parameter on the associated indicator on panel 27PCX-101 A, B is acceptable in lieu of !

taking grab samples. The monitoring will be performed using indicators on 27PCX-

101 A and B which are Regulatory Guide 1.97 qualified analyzers. If at least one j channel is not made operable within the following 30 day period, then the plant shall be placed in a mode in which monitoring is not required, (i.e., hot shutdown). The I completion time for this action is being changed from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months consistent I with the STS guidance. This proposed action is acceptable because even in the event that the recorder is inoperable, indication of the parameter will be available.

3 Note K to Table 3.2-8 is added for completeness. Since the proposed action statement specified in the revised Note F and the new Note K are comparable to the monitoring requirements of Specification 3.7.A.9, Specification 3.7.A.9 is unnecessary and, therefore, is being deleted from the Technical Specifications. The associated

surveillance requirements (Specification 4.7.A.9) have been incorporated into 4 Specification 4.2.H, " Accident Monitoring Instrumentation " Specification 4.7.A.9 is

, being deleted. These proposed changes are administrative in nature and will result in j the overall improvement to the Technical Specifications and will have no adverse 1 i safety effect. I i

} IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION i

i 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 4

would not:

1. involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes revise primary containment atmosphere monitoring requirements. The proposed changes adopt reference plant operating conditions (i.e.,

15% rated thermal power) for inerting /de-inerting requirement as well as for the drywell to torus differential pressure monitoring consistent with the NRC guidance provided in the Standard Technical Specifications. The FitzPatrick Technical

4 Attachment 11 to JPN-94-038 ,

SAFETY EVALUATION I Page 6 of 7 j Specifications currently allow a 24 grace period following startup or before shutdown in )

which the primary containment does not have to be inerted. During this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period required leak inspections as well as inerting or shutdown evolutions are

completed. Making the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " window" contingent upon core thermal power will ;

allow to place the mode switch in run sooner, removing startup neutron monitoring !

instrumentation scrams (i.e., APRM 15% and IRM upscale /inop). This reduces the probability of spurious trips due to spiking of this instrumentation. The proposed j changes do not involve physical modification to the plant nor involve any accident initiators. Therefore, the probability of an accident occurring remains unchanged. I Accident analyses contained in FSAR Chapter 14 assume that a LOCA occurs from full l power. The consequences of a LOCA below 15% rated thermal power would be less severe and would produce less hydrogen.

The proposed changes to Tables 3.2-8 and 4.2-8 will eliminate the reference to i Specifications 3.7.A.9 by moving the primary containment atmosphere monitoring j requirements from Specification 3.7.A.9 to Table 3.2-8, Note F. Note F is also revised

> such that if recorder 27PCR-101 A or B is inoperable, a daily monitoring and logging of ,

the appropriate parameter on the associated indicator on panel 27PCX-101 A, B is i acceptable in lieu of taking grab samples. The monitoring will be performed using indicators on 27PCX-101 A and B which are Regulatory Guide 1.97 qualified analyzers.

1 The proposed new Note K is added for completeness. These changes are administrative in nature and will improve the overall quality of the technical specifications. Therefore, the proposed changes do not involve a significant increase i in the probability or consequences of an accident previously evaluated. ;

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

The proposed changes revise primary containment atmosphere monitoring requirements by adopting STS guidance regarding inerting/de-inerting requirements, i

Consistent with this change the drywell to torus differential pressure monitoring requirement is being revised. Adopting the STS reference plant operating condition of 15% rated thermal power adds operational flexibility. The proposed changes do not l create the possibility of a new or different kind of accident from any accident previously

evaluated because the plant safety analyses assume that a LOCA occurs at full power.

In addition, several changes are proposed to Tables 3.2-8 and 4.2-8 which simplify hydrogen / oxygen monitoring requirements by moving the primary containment monitoring requirements from Specification 3.7.A.9 to Table 3.2-8. These changes are administrative in nature and will result in the overall improvement to the Technical Specifications. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

The proposed changes revise the primary containment atmosphere inerting/de-inerting

Attachment ll to JPN-94-038 i SAFETY EVALUATION !

Page 7 of 7 l i

requirements and the drywell to torus differential pressure monitoring requirement. The proposed change will allow inerting within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 15% rated thermal power during startup and de-inerting 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermal power to less than 15% of rated before a plant shutdown. These requirements are consistent with ,

the guidance provided in the STS. This proposed change does not affect the !

assumptions or conclusions' contained in the plant safety analyses which assume that a LOCA occurs from full power. The consequences of a LOCA below 15% rated thermal power would be less severe and would produce less hydrogen. The proposed changes to Tables 3.2-8 and 4.3-8 are administrative in nature. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

V. IMPLEMENTATION OF THE PROPOSED CHANGE Implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes affect the environmer.t.

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 ma! function of a type different from any previously evaluated in the Safety Analysis Report;

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

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

Vll. REFERENCES

1. NRC NUREG-1433, " Standard Technical Specifications General Electric Plants BWR/4," Revision 0, dated September 1992.

2. James A. FitzPatrick Nuclear Power Plant Final Safety Analysis Report Chapter 14,

" Safety Analyses."

ATTACHMENT lil to JPN-94-038 Markup of the current Technical Specifications pages Primary Containment Atmosohere Monitorina (JPTS-93-010) i l

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

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JAFNPP .

3.2 (cont'd) 42 (cont'd) t i

r E. Drywen Laak Ddartian 12. Drywell Leak Detection The limiting conditions of operation for the instrumentation that instrumentation shall be calibrated and checked as indicated in monitors dryweN iesk detection are given in Table 3.2-5. Table 4.2-5 F. (Deletec$ F. (Deleted)

G. RecirctAation Pump Trip G. RecirndMinn Pump Trip The limiting conc 9tions for operation for the instrumentation that instrumentation shall be functionally tested and calibrated as trip (s) the recirculation pumps as a means of limiting the indicated in Tabis 42-7.

W ahkeW an 6 System logic shed be functionefy tested as inc5cated in Table transient are given in Table 3.2-7. 4.2 7.

H. Accident Monitoring instrumentation Accident Monitoring instrumentation H.

The liminng candlems for operaum of the instrumente60n that instrumentahon shen be demonstrated operable by performance provides accident monitoring are given in Table 3.24. of achonnel channelcaNbr as ed in Table

1. 4kv Emergency Bus Ui&W Trip 4.24 ~

3 deld -

The umieng condidons for operadon for the instrumentadon that add [u"GbiF"I i prevents damage to electrical equipment or circuits as a result of either a degraded or loss-of. voltage concAtion on the emergency as afghca4/d electrical buses are given in Table 3.2-2.

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Amendment No. ljl6, Lild 181 s4

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*' c TABLE 3.2-8 (cont'd) .

ACCIDENT MONITORING INSTRUMENTATION No.of Ctennels Minimum No. of Modein WW2 Provided by Operable Channels Instrument Must instrument Design Required be Operable Action

8. TorusWater Level (Wide range) 2 1 Note J Note A (23U-202A or 23LR-202A/203A)

(23U-202B or 23tR-202B/2038)

9. Torus BukWeserTemperature 2 1 Note J Note A (1&1TI-131A or 1&1TR-131A)

(1&1TI-131B or 1&1TR-1318)

10. Torus Pressure 2 1 NoteJ Note A (27PR-101A) CA%uGE 70 -

(27PR-10181) P e u v e s urg/a u o v/-

11. Oxygen Concentration 2 1 Note Note F (27 -101A)

(27PCR-1018)

12. ReactorVessel Pressure 2 1 NoteJ Note A (06Pl41 A or 08PR41A) i (06Pl41B or 06PR41B)

13. Paacent Wager Level (fuel zone) 2 1 Note J Note A '

(02-3U491)

(02-3 tacos) i 14. Reactor Water Level (wide range) 2 1 NoteJ Note A (02-30-85A) l (02-3LmisB) i 1

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Amendment No.M , 181

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JAFNPP TABLE 3.2-8 (Cont'd) 1 ACCIDENT 840NUORING INSTRUWlENTATION NOTES FOR TABLE 3.2-8 /

. A. With the number of operable channels less than the required minimum, either restore the inaperable channels to operable status within 30 days, or be in a cold comSuon within #m next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

B. ' With the number of OPERABLE channels less then required by the minimum channels OPERABLE requirements, initiate an altamate method of monitoring the appropriate parameter (s) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and: (1) either restore the inoperable channel (s) to OPERABLE status within 7 days of the event, or (2) prepare and submit a Special Report to the Commission within 14 days following the event outNning the cause of the

, inoperability, the action taken, and the plans and schedule for restoring the system to OPERABLE status.

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C. Each Safety / Relief Vahe is equipped with two amandcol detectors, one of which is in service. Each SRV also has a backup thermocouple '

detector. In the event that a thermocouple is inoperable, SRV performance shall be monitored daily with the amenciasari in service am mHeal t

detector.

D. From and after the date that both of the am annical detectors are inoperable, continued operation is pomdemihaa untN the next outage in which a ~

primary containment entry is made provided that the thermocouple is opurable. Both acounbcal detectors shen be made operable prior to restart.

j E. in the event that both primary (==a=Hr=8 stasar*ws) and secondary (thern ecouple) indications of tids parameter for any one valve are disabled

and nedher irwaranan can be restored in forty-eight (48) hours, an orderly shutdown shah be initiated and the reactor shall be in a Hot Shutdown comStion in twelve (12) hours and in a Cold Shutdown within the next twenty-four (24) hours. -

!F. Sefer to Aparieranan 3.7.AJ.9 REPLME @W ST W l G. This parameter and associated instrumentation are not part of post-accident monitoring.

1 j H. This instrument shen be operable in the Run, Startup/ Hot Stan6y, and Hot Shutdown modes.

l J. This instrument shaN be operable in the Run and Startup/ Hot Staney modes.

!g.Icent T'en "6" !

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' knendment No.181, i

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TABLE a.:C.

MINIMUM TEST AND CAUBRATION FREQUENCY FOR ACCIDENT MONITORING INSTRUMEMATION i

instrument _

instrument Instrument Functional Test Calibrasion Frequency Check

1. Stack High Henge Egluent Monhor Once/ Operating Cycle Once/Operaung Cycle Once/ day

2. Turbine sundng Vent High Range Elguent Montor Once/ Operating Cycle Once/Operadng Cycle Once/ day ,

3. Radweste sundng Vent High Range BRuant Monhor Once/Operaung Cycle Once/Operedng Cycle Once/ day ,

4. Containment High Range R% Monbor Once/ Operating Cycle Once/Operadng Cycle Once/ day 2 Drywed Pressure (nomm range) N/A Once/Operaung Cycle Once/ day

! 5.

i 6. Drywed Pressure (wide range) N/A Once/Operanng Cycle Once/ day DryweN Temperature N/A Once/ Operating Cycle Once/ day l 7.

Torus Water Level (wide range) N/A Once/Operaung Cycle Once/ day i s.

Torus sukWaterTemperature N/A Once/ Operating Cycle Once/ day l 9.

10. Torus Pressure cwc r4 70 N/A Once/ Operating Cycle Once/ day A Peen,ev coumuswe>>r N/A Once/3 months Once/ day-

11. @t,4./ Oxygen Concentadon Analyzer Once/ day

12. ReactorVessel Pressure N/A Once/ Operating Cycle Reactor Water Lael puelzone) N/A Once/ Operating Cycle Once/ day

13. 1 Reactor Water Level (wide range) N/A Once/ Operating Cycle Once/ day l 14.

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i Amendment No. p, pIf, 181 M

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3.7 (cont'd) 4.7 (cont'd)

6. Oxygen Concentration 6. Oxygen Concentration The primary containment almosphere shen be T ;

l a. The primary containment oxygen concentration shall ,

reduced to less then four percent oxygen with ) be monitored as specilled in Table 42-8. l gl4g nitrogen gas during reactor power operadon wkh reactor cocient pressure above 100 peig, except as Re#McE cv /ra e4'gO apoclAed in 3.7.A.S.h. TExr ^O

b,, b. Within the 24 hr. period =W=rit to placing the "O reactor in the run modo logowing a shutdown, the containment almosphere oxygen concentrauon shaN be ratheart to less then 4 percent by weight and maintained in this condition. D% may commence 24 hr. prior to a shutdown.

7. Drywell-Torus DINorential Pressure

7. Drywe5 Torus DINorential Pressure l a.- The pressure dlNerential between the dryweN and

m. DiNorontial pressure between the dryweN and torus torus shall be monitored as specNied in Table 42-8.

shed be maintained at equel to or greater then 1.7 l i paid emospt as speci5ed in (t) and (2) below:

g_gg g,r-#

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i i i Amendment No. /,181 iso

_- _____.__.-,_...._..m.....- . _ _ _ _._ .._

.z JAFNPP ,

3.7 (Cont'd) 4.7 (Cont'd)

(1) IThis differential pressure shell be established j within a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period subsequent to placing ._y RE#4446 W ' TN I the reactor in the run mode. The differential '

Ex r "#

pressure may be reduced to less then 1.7 psid 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to e scheduled shutdown.

(2) The differential pressure may be decreased to less then 1.7 pold for a maximum of four (4) hours during required operability testing of the HPCI, RCIC, and * ; :::':-i Chamber -

Drywell Vacuum Brooker System.

(3) If the specifications of item e, above, cannot be met, and the differentiel pressure cannot be "7 ddM E d #

restored within the subsequent six (6) hour O T "6

l period the reactor shell be in e Hot Shutdown condition in six (6) hours and a Cold Shutdown condition in the following eighteen (18) hours.j cMag 70 5

8. If the specifications of 3.7.A.1 through 3.7.Ahonnot 8. Not applicable, be met the reactor shall be in the cold condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Amendment No. g. 192 180a

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3.7 (cont'd) .

4.7 (cont'd) .

9. Primary containment almosphere shen be contir==wmay (9.

Primary Containment Atmosphere Monitoring instruments monitored for hydrogen and oxygen when containment integrity is required. The excepson to this is when the a. Instrumentation shall be functionally tested and .; ,

poet. Accident Sampung System is to be operated. In this cahbrated as speci#ed in Table 4.2-8. /

Instance, the containmort atmosphere monitoring systems }

may be leolated for a period not to encoed 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months in a 24-hour period. The monitoring system shaN be ( _ _-

considered operable u at least one mormor is operable. ; g/g/g/g a) Frorn and after the time the primary containment atmosphere monitoring instruments are found or B. Stan@y Gas Treatment System made to be inoperable sor any reason, conunued raar*w operason is permissible sor the a-caa<e n gl 1. Standby Gas Treatment System surveiNance shaN be thirty (:q days unless one instrument monitanne : performed asindicated below:

each parameter is sooner made operable, provided l an appropriate grab sample is obtained and i a. At least once per operaung cycle, it shaN be analyzed at least once each twenty-four (24) hour j demonstrated that:

{> period.

(1) Rm dop acmsa h N @

b) If apar4areanri 3.7.A.9.a cannot be met, the reactor W h h k h h 5.7 she5 be placed in the cold conc 5 tion within twenty- ;

in. of water at 6,000 scim, and four @) h - j (2) Each 39kW heater shen dissipate greater than B. Stanchy GasTreatmentSystem gEf/fTb 29kW of electric power as calculated by the following expression:

1. Except as specised in 3.7.B.2 below both circuits of the P = 6 El Staney Gas Treatment System shall be operable at all %. -

times when secondary containment integrity is required.

P= Dissipated Electrical Power; E= Measured line-to-line voltage in volts (RMS);

i= Average measured phase current in amperes (RMS).

Amendment No. )6,26,;36, Sti,99, ei, Dif, 181 181

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Text "A" With the number of operable channels less than the required minimum, continued reactor operation is permissible for the following 30 days provided at least once each 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , either the appropriate parameter (s) is monitored and logged using 27PCX-101 A, B, or an appropriate grab sample is obtained and analyzed. If this condition can not be met, be in the Hot Shutdown mode within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Text "B" Primary containment atmosphere shall be continuously monitored for hydrogen and oxygen when in the Run and Startup/ Hot Standby modes, except when the Post-Accident Sampling System (PASS) is to be operated. When the PASS is to be operated, the containment atmosphere menitoring systems may be isolated for a period not to exceed 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months in a 24-hour period.

Text "C"

a. Primary containment oxygen concentration shall be less than four volume percent within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 15% of rated thermal power during startup.

b. De-inerting may commence up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermal power to less than 15% of rated before a plant shutdown.

Text "D" The primary containment oxygen concentration shall be verified to be within limits once each week. Instrument surveillances shall be performed as specified in Table 4.2-8.

Text "E" The pressure differential between the drywell and torus shall be verified to be within limits once each shift. Instrument surveillances shall be performed as specified in Table 4.2-8.

Text "F" The drywell to torus differential pressure shall be established within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of exceeding 15% rated thermal power during startup. The differential pressure may be reduced to less than the limit up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing thermal power to iess than 15% of rated before a plant shutdown.

Text "G" If 3.7.A.7.a above cannot be met, restore the differential pressure to within limits within eight hours or reduce thermal power to less than 15% of rated within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ;

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ML20071P611

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