ML20093N396

Proposed Tech Spec Changes Re NUREG-0737,Item II.K.3.18 Covering Implementation of Automatic Depressurization Sys Logic Mods

ML20093N396
Person / Time
Site:	FitzPatrick
Issue date:	07/25/1984
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20093N390	List: ML20093N389 ML20093N392 ML20093N396
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.18, TASK-TM NUDOCS 8408010322
Download: ML20093N396 (10)

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ATTACHMENT I

's, Proposed Technical Specification Changes Implementation of Automatic Depressurization System Logic Modifications Related to NUREG-0737 Item II.K.3.18 ,

New York Power Authority James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 O!

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JAFNPP TABLE 3.2-2 (Cont'd)

INSTRL' MENTATION THAT INITIATES OR CONTROLS THE CORE AND CONTAINMENT COOLI!G SYSTEMS Minimum No. Total of Operable Number of Instru-Instrument ment Channels Pro-Item Channels Per vided by Design for No. Trip System (1) Trip Function Trip Level Setting Both Trip Systems Remarks 5 2 Containment High 1< p < 2.7 psig 4 Inst. Channels Prevents inadvertent Pressure operation of contain-ment spray during accident condition.

6 1 Confirmatory Iow > l2.5 in. indicated 2 Inst. Channels ADS Permissive in Ievel level ( > 177 in.

conjunction with above the top of Reactor Low-Low-Iow active fuel) Water Level.

7 2 High Drywell < 2.7 psig HPCI Inst. Channels Initiates Core Spray Pressure LPCI, HPCI & SGTS.

l 8 2 Reactor Low Pres- 2450 psig 4 Inst. Channels Permissive for opening sure Core Spray and LPCI Admission valves.

l Amend =ent No. J C J,6 g 67 I

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JAFNPP 1

TABLE 3.2-2 (Cont'd)

I!sTRUME?TTATION THAT INITIATES OR CONTROIS THE CORE AND CONTAI!MEh"r COOLING SYSTEMS Mini = rum No. Total of Operable Number of Instru-Instrument ment Channels Pro-Ites Channels Per vided by Design for No. Trip System (1) Trip Function Trip Level Setting Both Trip Systems Remarks 9 1 Reactor Low Pres- 50 I p I 75 psig 2 Inst. Channels In conjunction with sure ECIS signal permits closure of RHR (LPCI) injection valves.

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11 THIS ITEM IfrTE!TTIONALLY BIAIK 12 1 Core Spray Pump 11 + 0.6 sec. 1 Inst. Channel Initiates starting (See Note 3) Start Timer of core spray pumps.

(each loop) (each loop)

Amendment No. J/4 g 68

JAFNPP TABLE 3.2-2 (Cont'd)

INSTRIMENTATION THAT INITIATES OR CONTROLS THE CORE AND CONTAI!BIENT COOLING SYSTDtS l

Minimum No. Total of Operable Number of Instru-Instrument ment Channels Pro-Item Channels Per vided by Design for No. Trip System (1) Trip Function Trip IAvel Setting Both Trip Systems Remarks 13 1 RER Pump Start Timer (See Note 3) 1st Ptsap (A Loop) 1.0 + 0.5 (-) O sec. 1 Inst. Channel Starts 1st Pump -(A Loop) 1st Pump (B Loop) 1.0 + 0.5 (-) O sec. 1 Inst. Channel Starts 1st Pump (B Loop) 2nd Pump (A Icop) 6.0 1 0.5 sec. 1 Inst. Channel Starts 2nd Pump (A Imop) 2nd Pump (B Loop) 6.0 1 0.5 sec. 1 Inst. Channel Starts 2nd Pump (B Loop) 14 1 Auto Blowdown Timer 120 see 1 5 sec. 2_ Inst. Channels Initiates ADS, in conjunction with Low-Low-Iow Reactor Water .

I Level, and LPCI or .

Core Spray Pump dis-charge pressure inter-lock, if not inhibited by ADS override I switches.

15 2 RHR (IPCI) Pump 125 psig i 20 psig 4 Inst. Channels Defers ADS actuation Discharge Pressure pending confirmation Interlock of low pressure core cooling system opera-tion.

Amendment No. / % g 69 i _

i 3.5 (cont'd) JAFNPP 4.5 (cont'd) l l

D. Auto =atic Depressurization System D. Automatic Depressurization System (ADS) (ADS)

1. The ADS shall be operable whenever 1. Surveillance of the Automatic the reactor pressure is greater Depressurization System shall than 100 psig, and irradiated fuel be performed during each operating is in the reactor vessel and prior cycle as follows:

to reactor startup from a cold  !

condition, except as specified a. A simulated automatic initiation below: which opens all pilot valves.

a. From and after the date b. Manually open each relief / safety that one of the seven valve while bypassing steam to relief / safety valves of the condenser and observe a > IO *o/

the ADS is made or found closure of the turbine bypass ~

to be inoperable for any valves, to verify that the reason while it. is required, relief / safety valve has opened.

continued reactor operation is permissible only during c. A simulated automatic initiation the succeedi.ng 30 days unless which is inhibited by the override repairs are made and provided switches. l that during such time the IIPCI System is operable.

b. From the time that more than one of the seven relief / safety valves of the ADS are made or found to be inoperable for any i reason, continued reactor opera-tion is permissible during the succeeding 24 hrs, unless repairs are made and provided, that l

Amndent No. [ 119 1

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JAFNPP .

TABLE 3.2-2 o

INSTRUMENTATION THAT INITIATES OR CONTROLS THE CORE AIO CONTAlfGGENT COOLING SYSTEMS Mnimusa No. Total of Operable Number of Instru-Instrument ment Channels Pro-Itest Channels Per vided by Design For No. Trip System (1) Trip Function Trip Level Setting Both Trip Systems Remarks ,

1 2 Reactor Int-Int > -38 in. indicated 4 HPCI & RCIC Initiates HPCI, l Water Level ' level ( 1 126.5_in. Inst. Channels RCIC & SGTS.

l above the top of active fuel) 2 2 Reactor Zar-Iot- 1-146.5in. indicated 4 Core Spray & RHR Initiates Core Spray, Int Nater Level level ( 1 18 in. Instrument channels LPCI, and Emergency above the top of Diesel Generators, active fuel) 4 ADS Instrument Initiates ADS in Channels conjunction with confirmatory low level, 120 second time delay and LPCI cr Core Spray pump discharge pressure i

interlock if not inhibited by ADS override switches.

3 2 Reactor High Water -(+58 in indicated 2 Inst. Channels Trips HPCI and RCIC Level level ($ 222.5 in. Turbines. .

above the top of I active fuel) 4 1 Reactor Iot Imvel )+352 in, above

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2 Inst. Channels Prevents inadvertent  ;

operation of contain-(inside shroud) vesselzero(10in. ment spray during above the top of active fuel) accident condition.

Amendment No. Jg,)[, [ 66

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ATTACHMENT II Safety Evaluation of Proposed Changos to Technical Specifications - Implementacion of Automatic Depressurization System Logic Modifications Related to NUREG-0737 Item II.K.3.18 1

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New York Power Authority James A. Fit 2 Patrick Nuclear Power Plant Docket No. 50-333 I

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1. Description of the Change A new Section' 4.5.Df l.c has been added on page 119 that requires surveillance testir.g of the Automatic Depressurization System (ADS) override switches'once per operating cycle. Reference 2 specified a .that a survei.11anc'e olan for the manual inhibit switch (override) a should be irkluded ih the Technical Specifications.

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1' Four, changes were made to Table 3.2-2 (" Instrumentation That

' Initiates or s Controls the Core and containment Cooling Systems") on pages 66-69:

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- 'Oavpage Cd, Item No. 2 (Reactor Low-Low-Low Water Level Trip Fdaction/ eliminates "...high drywell pressure..." from the

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remarkusssociated with the ADS instrument channels and adds the phr'ase "if not inhibited by ADS override switches". The plant modification associated with NUREG-0737 Item II.K.3.18 removes the high diywell pressure permissive for ADS actuation.

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.5 On page 67, Item No. 6 (Confirmatory Low Level) the remarks i entry is revised to clarify the remark. The phrace "in i conjunction with reactor Low-Low-Low Water Level" has been add d.

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$ ,On page 68, Item No. 11 (High Drywell Pressure) has been deleted in its entirety since this signal has been eliminated

- - as ahpermissive for ADS actuation.

'l On page 69, Item 14 (Auto Blowdown Timer) the phrase "...high drywell pressure..." was deleted from the remarks entry to 9

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reflect the elimination of high drywell pressu;e as an ADS actuation permissive. In addition, the phrase "...if not inhibited by the ADS override switches" has been added to the remark to reflect the addition of these new switches.

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. II. Purpose of the Change

• Item II.K.3.18 of NUREG-0737 (as clarified by Reference 5) stated the NRC's position that "the ADS actuation logic should be modified to eliminate the need for manual actuation to assure adequate core cooling.- A feasibility'and risk assessment study is required to determine the optimum approach."

\ Elimination of the high drywell pressure permissive from the ADS actuation logic will ensure adequate core cooling for those transient or accident events that do not directly produce high drywell pressure (e.g. stuck open relief valve or steam line break outside containment) and are degraded by a loss of high pressure codlant systems. Elimination of the high drywell permissive for ADS actuation and the addition of manual " inhibit" or " override" switches fulfills the NRC criteria (Ens.-losure l-to Reference 2, p.

3). Furth'er, the inhibit switches permit the operator to override ADS actuation logic if the operator confirms the signals are

erroneous or if-reactor water level can be restored.-

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. l The installation of a new ADS actuation inhibit switches allow the operator to prevent or delay ADS actuation. This is in accordance

.with Emergency Procedures Guidelines (EPGs) which have been I approved by the NRC staff (Reference 7). If conditions and EPGs require that the operator initiate a reactor vessel blowdown (or initiate ADS), the operator can also initiate blowdown by turning individual safety / relief valve (SRV) switches, or allow ADS to be actuated by positioning the override switches in their " normal" position.

Via Reference 4, the BWR Owners' Group (BWROG) sent to the NRC a study of alternatives to the present ADS actuation logic. This report also identified modifications that would eliminate the need for manual ADS actuation during postulated accident conditions to ensure core coverage. In Reference 6 the Authority formally endorsed this report.

The NRC evaluated the Owners' Group report and concluded that two of the seven alternatives were acceptable (Reference 3). The Authority subsequently decided to implement the first of these two acceptable alternatives - elimination of the high drywell pressure permissive and the addition of a manual inhibit switch (Reference 1).

The NRC closed the issue, finding the proposed modifications acceptable, (Refarence 2) based upon the Authority's commitment to complete the modifications by April 30, 1985.

III. Impact of the Change The Authority considers that this proposed amendment can be classified as not likely to involve significant hazards considerations since it is a change to make a license conform to regulatory criteria where the license change results in very minor changes to facility operations. This is very similar to and clearly in keeping with Example (vii), Federal Register, Vol. 48 No. 67 dated April 6,1983, page 14870 and 10 CFR 50.92.

IV. Implementation of the Changes Implementation of the changes, as proposed, will not impact the ALARA or fire protection programs at FitzPatrick, nor will the changes impact the environment.

V. Conclusion The incorporation of these changes: a) will not increase the probability or the consequences of an accident or malfunction of equipment important to safety.as evaluated previously in the Safety Analysis Report; 'b)-will-not increase the possibility of an accident or malfunction of a Cfre.other than that evaluated previously in the Safety Analyst 3 Report; c) will not reduce the margin of safety'as defi'ned in the basis for any Technical Specification; d) does not constitute an unreviewed safety question, and e) involves no Significant Hazards Consideration, as defined in 10 CFR 50.92.

c, VI. References

.l.- NYPA letter, J. P. Bayne to D. B. Vassallo, dated-l July 25, 1984 (JPN-83-70) regarding modification of ADS Logic, NUREG-0737, Item-II.K.3.18.

2. NRC letter, D. B..Vassallo to J. P. Bayne, dated June 3, 1983 regarding NUREG-0737, Item II.K.3.18, ADS Logic Modifications.. Includes NRC Evaluation of BWROG Generic- Response to NUREG-0737, Item No.

II.K.3.18.

3. NRC letter, D. B. Vassallo to J. P. Bayne,' dated June 5, 1984 regarding response to_NUREG-0737, Item II.K.3.18.

4. BWR Owners' Group letter, T. J.-Dente to D. G. Eisenhut, dated October 28, 1984 (BWROG-8260) transmits report "BWR Owners' Group Evaluation of NUREG-0737, Item II.F.3.18 Depressurization System Logic" February 1983, NEDE-30045..

5. NRC letter, D. G. Eisenhut to All Licensees, dated September 5, 1980 regarding Preliminary Clarification of TMI Action Plan Requirements, Item II.K.3.18

" Modification of ADS Logic - Feasibility for Increased Diversity 1for Some Event Sequences" of NUREG-0737.

6. PASNY letter, J. P. Bayne to D. B. Vassallo, dated March 31, 1983 (JPN-83-29).

7. NFC letter, D. G. Eisenhut to All BWR Licensees, dated February 8, 1983 regarding Safety Evaluation of " Emergency Procedure Guidelines, Revision 2", NEDO-24934,. June 1982.

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