ML20079K373

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Proposed Tech Specs,Updating RHR Pump Surveillance Test Acceptance Flow Rate from 9900 to 8910 & Spec Added in Amend 168 to Reflect Amend 171
ML20079K373
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 10/11/1991
From:
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20079K366 List:
References
JPTS-91-013, JPTS-91-13, NUDOCS 9110220160
Download: ML20079K373 (7)
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i ATTACHMENTIto JPN 91457 r

PROPOSED TECHNICAL SPECIFICATION CHANGES l MODIFICATION OF RHR FLOW RATE REQUIREMENTS i (JPTS 91013) {

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JAMES A. FITZPATRiCK NUCLEAR POWER Pl. ANT i Docket No. 50 333 91102';:0160:911011 'e .

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ll. PURPOSE OF THE PROPOSED CHANGE This application for an amendmont to the James A. FitzPatrick Tochnical Specifications proposos an administrativo chango to updato tho Rosidual Hoat Romoval (RHR) pump survolllanco test acceptanco flow rato from 9900 to 8910 gpm on page 122. This pa00 was part of Amendment 168 (Referenco 1) which was addod to incorporato now oporability toqu!romonts, survoillanco requiremonts, and corresponding bases for minimum Emergoney Coro Cooling System availability when the plant is in the cold shutdown condition. A subsequent submittal was mado (Referenco 2) to modify the RHR pump survoillance tost acceptanco flow rato for porlodic testing but was based upon tho Tuchnical Spocifications existing boforo approval of Amondmont 168. This submittal was approvod as Amendmont 171 (Referenco 3). This proposud chango will updato tho Specitication added in Amendmont 168 to reflect Amonomont 171.

The Emergency Coro Cooling System (ECCS) for the FitzPatrick Plant consists, in part, of the Low Prossuro Coolant injection (LPCI) modo of the RHR system. LPCI is comprised of two subsystems (loops) with each LPCI subsystem consisting of two motor driven RHR pumps and piping and valvos to transfor water from the supprossion pool to the reactor vossol.

The RHR pumps are testod in accordanco with Section XI of the ASME Bollor & Pressuro Vossol Codo (Referenco 4) and Specification 4.5.A.3 to ensuro that adoquato omorgency coro cooling capacity is availablo prior to and after startup from the cold condition. Tho RHR pumps aro testod in accordanco with Specification 4.5.F.1 to 0.isuro that adoquato omorgency coro cooling capacity is available during the cold condition. The curront critorion of Specification 4.5.A.3 is that flow for cach pump must be at least 8910 gpm against a system head corrospending to a reactor vossol to primary containment difforontial pressure of at least 20 psid. The curront critorion of Specification 4.5.F.1 I

Attachment il to JPN 91457 SAFETY EVALUATION Pago 2 0f 5 speciflos a flow of 0900 gpm eDalnst tho samo system head. Tho chan00 to Spocification 4.5.F.1 will make tho spocifications consistent.

As discussed in Amondment 171 the RHR pumps are on tha stoop part of tholr head capacity curves (l.c., near runout flow) at 9900 gpm. In this region of the pump curvo, small variations in flow rosult in non proportional largor variations in prossuro. Tho lower minimum allowablo RHR pump flow rato (0910 gpm) will reduco tho offect of flow measuremont uncortaintics. Futuro pump tosts will b6 moro ropoatablo and pump degradation moro readily detectod. The proposed chango to Spocificotton 4.5.F.1 also maintains consistency betwoon pump test roqultomonts for all modos of oporation.

Ill. SAFETY IMPLICATION OF THE PROPOSED CHANGE This proposed change reduces the RHR survoillanco test acceptanco flow rato during the cold condition from 9900 gpm to 8910 gpr? This proposed chango is tho Samo as Amendmont 153 (Rotorenco 5) to tho FitzPatrick Tochnical Spocifications which changed the survolitanco tost flow acceptanco value for tho "A" and 'C' RHR pumps from 9900 gpm to 8910 gpm (a decreaso of 10%). The Authority's application for Amendmont 153 (Reforenco f) was limitod to tho 'A' LPCI subsystem and for the duration of operating cyclo 9 because of the ov,lgont natur1 of tho amondment application. Araondmont 171 rnado this temporary chango permanont. This proposod chango will updato Amondmont 168 which was approved during the pondency of Amendmont 171 to roflect a RHR pump sur/olllance test acceptanco flow rato idontical to that proviously accepted as part of Amendmont 171. This proposed chango is admir.!strativo in natuto duo to the prior acceptanco of equivalent changos in Amondmont 171.

The justif! cation for a 10 porcont flow reduction in the application for Amendment 153 and Amendment 171 was the FitzPatrick SAFER /GESTR Appondix K LOCA analysis (Referenco 7) supplomonted by a sensitivity study of the plant (Referenco 0) and a safety evaluation (Referenco 8). Togother, thoso analysos substantiated continuod operation with an allowab'o survoillanco test acceptanco flow rato of 8910 gpm. Tho key issues woro:

. Sonsitivity studios porformod with tho SAFER /GESTR Appor, dix K LOCA models demonstrato an increaso in fuol peak cladding temperaturo (PCT) of 88 F for a 10%

toduction of all ECCS flow ratos. Sinco the curront limiting licensing PCT is moro than 600 F below the 2200*F allowablo limit, tho FitzPatrick plant continuos to moot the requirements of 10 CFR 50.46 and 10 CFR 50, Appendix X with over 500*F of margin.

. General Electric Co. (GE) has estimated a cilght increaso in PCT (loss than or equal to GOT) for tho worst caso Appendix R firo assuming a 10% decreaso in LPCI flow rato. Since the calculated fuel PCT for this event was 1013'F, which is well below l

temperatures associated with fuel cladding damago, tho FitzPatrick plant continuos l to moot the requiroments of 10 CFR 50, Appondix R. This analysis was tho buls for l

an oxomption request (Referenco 13) to allow an operator responso timo of 30 minutos to initiato romoto shutdown following a Control Room fire.

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l Attachmant il to JPN 91-057 1 SAFETY EVALUATION ,

Pago 3 of 5

. An ovaluation of the other operating modos of RHR (1.0,, cupprossion pool cooling, docay hoat romoval, and containment spray cooling) shows that the RHR pumps operating at 8910 gpm excood the dosign and FSAR flow ratos for thoso modos. In other words, thoro is no effoct on tho other RHR nporating modos bocause the design of the RHR pumps is based on tho moro limiting iequitomonts of the LPCI modo.

This chango is administrativo and thoroforo tho offoct of this proposed Amendmont is encompassed by tho discussion in the applications for Amendmonts 153 and 171. Tho applicatlons br Amondmonts 153 and 171 noted that the resultant offoct of changing tho ,

RHR pump survoillance test flow acceptanco valuo from 0900 gpm in 8910 gpm was twofold:

. First, thoro was an insignificant docroato in tho safety margins associated with ECCS porformanco following a LOCA and with reactor inventory makoup capability during postulated Appendix R ovents.

. Socondly, testing tho RHR pumps at 8910 gpm would otiminato problems inhoront in testing the pumps noar runout flow conditions. Tho tost flow rato of 0000 opm is approximately 30% greator than the pump's design point of 7700 ppm and only G%

below runout flow conditions (10,500 Opm).

Operation of the plant in the cold condition in accordanco with the proposed Amendmont is not a safoty concern. Tho conclusions of the plant's accident analysos as documented in the FSAR or the NRC Staff's SER are not attorod by thoso changes to the Technical Spocifications. As committod to in tho application for Amondmont 171, the Authority is presently revising the licensing basis SAFER /GESTR ECOS performanco analysis which .

was portormod following start up in the 1991 rofueling outago. Tho updated analysis will )

contain LPCI flow changos.

IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION ,

Operation of tho FitzPatrick p; ant in accordanco with the proposod Amendment would not involvo a significant hazards considoration as definod in 10 CFR 50,92, sinco it would not:

1. Involvo a significant increaso in the probability or consequences of an accident proviously evaluated.

This proposod chango is administrativo in naturo and consistont with a previous Amendmont to tho James A. FitzPatrick Technical Specifications.

L As proviously noted in the Amondmont 171 safoty ovaluation, the oflect of loworing l the flow rato of tho RHR pumps has boon fully analyzod. Tho chango in flow rato l cannot increase the probability of a previously ovaluated accident. Tho analysis shows that the consequences of postulated accidents romains well within the acceptablo limits set forth in the FitzPatrick FSAR and fodoral regulations. Tho 88'F l

Attachmont il to JPN 91057 SAFETY EVALUATION Pago 4 of 5 expoctod incrcaso in PCT is not significant with respect to tho existing 000*F margin to the 2NF acceptanco critoria.

2. croato the possibility of a now or difforont kind of accidont f om any accident previously evaluated.

This proposed chango is administrativo in naturo and consistont with a previous Amondmont to the James A. Fl'.zPatrick Tochnical Specifications. This proposed chango will not requiro any mocifications to any plant structuros, systoms, and compononts. This proposed chango will meroly cortoct an administrativo error so tho Technical Specifications will romain consistent with prior Amendmont 171. This chango cannot inlllato or contributo to any now or d;fforent kind of accidont from any accidont provlously ovaluatod.

3. Involvo a t,lgnificant roduction in a marDin of refoty.

This proposed chango is administrativo in nataro and consistent with a provious amondmont to the James A. Fit 2 Patrick Tochn: cal Spocifictsions. As such 11 roflects a previously approved reduction in the margin of safoty. As notod in Amendmont 171, the 10% toduction in RHR flow to 8910 gpm would resuh in a ca:culated PCT increaso of 88"F which is not significant considoring tho 000"F margin to the ECCS acceptanco critoria of 220CTF.

V, IMPLEMENTATION OF THE PROPOSED CHANGE The proposed chango to Specification 4.5.F.1 is administrativo in naturo and reduces tho RHR pump survoillance tost acceptanco flow valuo. Tho natuto of this chango is such that no additional personnel occupancy timo is anticipated for pump testing which could offoct ALARA by increasing dosos. Thore will be no changos to structures, sysicms or ce 1pononts that could offoct tho analytical bases or proceduros for the Al. ARA and Tiro Protection Programs. The 10% flow reduction offects the calculated PCT lor tho worst caso Appondix R firo but tho increaso is well within plant allowables and wl!I roqu!ro no aoditional action. The RHR pump surveillanco tests do not result in dischargos to tho environment sinco testing is performod in the RCIC modo (Reforonco 11) and as such will havo no offoct on tho environmont. It is concludod that implomontation of the proposod chango will not advorsoly affect the ALARA or Firo Protection Pro 0 rams at the FitzPatrick plant, nor will tho chango affoct tho environmont.

VI. CONCLUSION l The chango, as proposod, will not constituto an unroviewod safoty question as iofinod in 10 CFR 50.59. That is,it:

, i Attachment 11 to JPN 91057 SAFETY EVALUATION Page 6 of 5 -

L L 1.- will not change the probability nor the consoquences of an accident or malfunction of equipment important to safoty as previously evaluated in the Safety Analysis i' Report;

2. will not increase the possibility of an accident or malfunction of a type different from l any previously evaluated in the Safety Analysis Report; l 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 definod in 10 CFR 50.92.

re Vll. - l REFERENCES

1. Amendment 168 to the James A. FitzPatrick Operating Uconso, February 13,1991,
2. NYPA letter, J.C. Brons to the NRC, dated June 21,1990, (JPN 90-049), requesting changes to the RHR Pump Technical Specifications.

3.' . Amendment 171 to the James A. FitzPatrick Operating Uconso, July 1,1991.

l - 4. ASME Bollor & Pressure Vessel Code,Section XI,1980 Edition through Wintor 1981 H Addenda.

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5. Amendment 153 to the James A. RtzPatrick Operating Uconso, February 28,1990, p '6. NYPA letter, J.C. Brons to 11,o NRC, dated February 9,1990 (JPN 90-013),

requesting changes to the RHR Pump Technical Specifications on an exigent basis.

7. James A. FitzPatrick Nuclear Power Plart. SAFER /GESTR LOCA 1.oss of Coolant
Accident Analysis, NEDC 31317P, dated Octobor 1986, i 8. _ Sensitivity of the James A. RtzPatrick Nuclear Power Plant Safety Systems Performance to Fundamental System Parameters, Proprietary General Electric

.. Report, MDE-83-0786, dated July 1986.-

S. James A. FitzPatrick Nuclear Power Plant, Nuclear Safety Evaluation for a 10% '

Decreas ti a LPCI Flow, (JAF SE 90-024), dated February 5,1990, prepared by General Electric Co. and approved by the Now York Power Authority, b 10. James A. FitzPatrick Nuclear Power Plant Operatbns Survoillance Test Proceduro, t

ST 2A, 'RHR Pump Flow Rate and ' inservice Test

  • Revision 32, dated July 18,1991.

._ 1 1. ~

James A. FitzPatrick Nuclear Power Plant Updated Final Safoty Analysts Report

_ Chapter 6.

l- 12. . James A. FitzPatrick Nuclear Power Plant Safoty Evaluation Report (SER), dated L N J,'em, v 20,1972, and Supplomonts.

13. N ' Pale ar, J.C, Brons to the NRC, dated December 17,1985, (JPN 85 90),

- reqm ng an Exemptlon to 10 CFR 50 Appondix R rogarding Attornato Shutdown Capability.

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