ML20086C094
| ML20086C094 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/19/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20086C079 | List: |
| References | |
| NUDOCS 9507060273 | |
| Download: ML20086C094 (5) | |
Text
_
g5 **ou f
UNITED STATES j
j-NUCLEAR REGULATORY COMMISSION t.
WASHINGTON, D.C. 20066 4001 k * * * * *,/
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT WO. 225 TO FACILITY OPERATING LICENSE NO. DPR-59 POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333
1.0 INTRODUCTION
By letter dated February 22, 1995, the Power Authority of the State of New York (the licensee) submitted a request to change the James A. FitzPatrick Nuclear Power Plant (FitzPatrick) Technical Specifications (TSs). The proposed change to the FitzPatrick TSs would modify operability and surveillance requirements for the reactor vessel overfill protection instrumentation that initiates feedwater pump turbine and main turbine trips-on high reactor vessel water level.
2.0 BACKGROUND
In a letter dated September 20, 1989, the NRC. staff issued Generic Letter-(GL) 89-19, " Request for Action Related to Resolution of Unresolved Safety Issue (US1) A-47."
As part of the technical resolution of USI A-47, the NRC concluded that all boiling-water reactors (BWRs) should provide automatic reactor vessel (RV) overfill protection and that plant procedures and TSs should include provisions to periodically verify the operability of the overfill protection system during reactor power operation.
By letter dated August 5,1994, the licensee submitted its implementation schedule for the recommendations of GL 89-19. By letter dated June 30, 1994, the NRC staff concluded that the FitzPatrick plant did "not have appropriate Technical Specifications (TS) governing the availability of the main feedwater overfill protection system instrumentation," and that "the TS should be revised to reflect the plant as-built configuration." The NRC staff requested that the licensee revise the FitzPatrick TS to "be similar to the General Electric Standard Technical Specifications (STS) that were applicable at the time the staff issued Generic Letter 89-19" (September 20,1989). The applicable STS for FitzPatrick is NUREG-0123, Rev. 3.
However, in lieu of the STS presented in NUREG-0123, the licensee elected to model the proposed changes to the 1S on the most recent STS approved by the NRC, contained in NUREG-1433.
The FitzPatrick plant utilizes three instrument channels that sense reactor vessel water level, and initiate a trip of the two feedwater pump turbines, and the main turbine, on high reactor vessel water level. The three channels-provide input to a two-out-of-three initiation logic. The proposed changes incorporate operability and surveillance requirements into the TS that conform, with one exception, to the STS. The exception applies to the 9507060273 950619 PDR ADOCK 05000333 P
. frequency of the instrument functional test. The STS specifies a quarterly frequency for this test. The design of the FitzPatrick trip system does not permit functional testing of this trip function without lifting electrical leads. Consequently, testing this trip system on-line poses an unacceptable risk of an inadvertent trip of the feedwater pump turbines and main turbine, i
resulting in a plant transient. The proposed TS change has a frequency that permits the testing to be accommodated during plant shutdowns. The proposed I
surveillance interval for the instrument functional test will permit testing while the plant is shutdown, avoiding the risk of a plant transient. As proposed, a functional test will be performed each refueling outage, and each time the plant is in cold shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The testing requirement during shutdown may be waived if the test has been performed during the previous 92 days. The 92-day limit corresponds to a quarterly frequency.as defined in the STS, and avoids the risks of plant transients associated with excessive testing.
j 3.0 PROPOSED TS CHANGES The proposed changes add limiting conditions for operation (LCOs) and i
surveillance requirements for the feedwater system isolation instrumentation!.
to TS 3/4.2, " Protective Instrumentation." The proposed changes are:
1.
Add. Specification 3.2.F as follows:
"Feedwater Pa= Turbine and Main Turbine Trio i
The limiting conditions for operation for the instrumentation that provides a feedwater pump turbine and main turbine trip are given in Table 3.2-6"
{
2.
Add Specification 4.2.F as follows:
"Feedwater P"- Turbine and Main Turbine Trio Instrumentation shall be tested and calibrated as indicated in Table 4.2-6" 3.
Add the following description of the rractor vessel water level trip i
function to Section 3.2 Bases-
"Three channels of the Reactor Vess21 Water Level - High instrumentation are provided as input to a two-out-of-three initiation logic that trips the two feedwater pump turbines and the main turbine. An event involving excessive feedwater flow results in a rising reactor vessel water level, which upon reaching the reactor vessel water level trip setpoint, results in a trip of both feedwater pump turbines, and the main turbine. The feedwater pump turbine trip under these conditions limits further increase in the reactor vessel water level due to feedwater flow. A trip of the main turbine protects the turbine from damage due to excessive water j
carryover."
I i
. l 4.
Add Table 3.2-6, "Feedwater Pump Turbine and Main Turbine Trip Instrumentation Requirements." The table establishes operability requirements for the reactor vessel high water level trip function for the feedwater pump turbines and the main turbine. The addition establishes a minimum number of operable channels of three instrument channels when the reactor power is greater than or equal to 25% rated thermal power, and a trip level setting of less than or equal to 222.5 inches above top of i
active fuel (TAF). An allowable out-of-service time (A0T) of 7 days is permitted by note I with one less than the minimum number of operable instrument channels, before the channel must either be restored to an operable status or placed in the tripped condition. The A0T for two or more inoperable instrument channels is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Failure to meet these i
limiting conditions for operation requires a reduction in reactor power to less than 25% rated thermal power within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Note 2 provides a 6-hour A0T to_ perform required surveillances provided the trip function maintains feedwater pump turbine and main turbine trip capability.
5.
Add Table 4.2-6, "Feedwater Pump Turbine and Main Turbine Trip Instrumentation Test And Calibration Requirements." The table establishes the surveillance requirements for the reactor vessel high water level trip function for the feedwater pump turbines and the main turbine as follow:
Instrument Functional Test Frequency: Note 1 Logic System Functional Test: Once every 24 months Instrument Calibration Frequency: Once every 24 months Instrument Check Frequency: Daily Note 1. Perform the instrument functional test:
a.
During each refueling outage, and b.
Each time the plant is in cold shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous 92 days.
6.
Define the instrument functional test with note 2 as follows:
"This instrumentation is exesipt from the instrument channel functional test definition.
The functional test will consist of injecting a simulated electrical signal into the instrument channel as close to the sensor as practicable."
4.0 EVALUATION The design of the FitzPatrick trip system does not permit functional testing of this trip function without lifting electrical leads. Consequently, testing this trip system online poses an unacceptable risk of an inadvertent trip of l
4
_m
]
4 i
1 the feedwater pump turbines and main turbine, and subsequent scram. The proposed surveillance interval for the instrument functional test will permit testing while the plant is shutdown, avoiding the risk of a plant transient.
As proposed, a f9nctional test will be performed each refueling outage, and each time the plant is in cold shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
.j The testing requirement during shutdown may be waived if the test has been performed during the previous 92 days. The 92-day limit corresponds to a quarterly frequency as defined in the STS, and avoids the risks of plant transients associated with excessive testing.
Limiting instrument functional testing to plant shutdown opportunities is similar.to that approved in GL 91-09. The GL provided an alternative testing i
schedule to the semi-annual surveillance requirement for the electrical protection assemblies used in the power supplies for.the reactor protection system. As stated in'GL 91-09, the recommended alternative is to-test the system each time the plant is in cold shutdown for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the test has not been performed within the previous 6 months.
The feedwater pump turbine.and main turbine trip function is currently functionally tested once everyig erating cycle. The proposed TS will result -
in more frequent testing of the. trip system when considering the likelihood of i
scheduled and unscheduled mid-cycle outages.
The nature of the instrument functional tests is defined by note 2 on Table 4.2-6 which reads: "The instrumentation is exempt from the instrument channel functional test definition. The functional test will consist of injecting a simulated electrical signal into the instrument channel as close to the sensor as practicable." The testing, as defined by the note, recognizes the impracticability of injecting a known signal into the reactor vessel level sensors. The note is consistent with note 5 on page 84 of the FitzPatrick TS which applies to most of the instrument functional test requirements.
i Further, the note is consistent with the definition of " Channel Functional Test" presented in Section 1.1 of NUREG-1433 STS.
1
.NUREG-1433 STS specifies a frequency for the calibration and logic system functional test (LSFT) of the trip system that is consistent with the length of the plant-specific fuel cycle. Since the FitzPatrick fuel cycle is based on a 24-month period, the frequency proposed for the calibration and LSFT has been selected to coincide with this period.
Based on the above, the NRC staff has determined that the proposed TSs changes-will have no adverse impact on plant safety and will enhance the current TSs
-by adding operability requirements for the RV overfill protection system.
Therefore, the staff concludes that the proposed TS change is acceptable.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.
, 6.0 ENVIRoletENTAL CONSIDERATION The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined
{
that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative
)
occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (60 FR 24gl5). Accordingly,.the amendment meets the eligibility criteria for i
categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR t
51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner,-(2) such <
activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security cr to the health and safety of the public.
Principal Contributor:
C. E. Carpenter Date:
June 10, 1995 i
I ii
- - - - - - - - - - - - -