ML20094R698

Proposed Tech Specs,Extending Surveillance Test Intervals for SLC Sys to Support 24 Month Operating Cycles

ML20094R698
Person / Time
Site:	FitzPatrick
Issue date:	11/30/1995
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20094R695	List: JPN-95-051, Application for Amend to License DPR-59,proposing to Extend Surveillance Test Intervals for SLC Sys to Support 24 Month Operating Cycles ML20094R698 ML20094R700
References
NUDOCS 9512050109
Download: ML20094R698 (22)

Text

I JAFNPP .. - -I i

I 3.4 LIMITING CONDITIONS FOR OPERATION 4.4 SURVEILLANCE REQUIREMENTS , 3.4 STANDBY LIQUID CONTROL SYSTEM 4.4 STANDBY LIQUID CONTROL SYSTEM l

Anolicability: Anchcabihty:

Applies to the operating status of the Standby Liquid Control Applies to the periodic testing requirements for the Standby Liquid System. Control System.

Obiective: Obiective To assure the availability of a system with the capability to shut To verify the operability of the Standby Liquid Control System.

dswn the reactor and maintain the shutdown condition without control rods.

Snecification:

Specifications A. Normal Operation .

A. Normal Operation

]$G During periods when fuel is in the reactor and prior to The operability of the Standby Liquid Control System shall be verified by performance of the following tests:

startup from a cold condition, the Standby Liquid Control

,h$ System shall be operable except as specified in 3.4.B 1. Once oer month - l no below. This system need not be operable when the reactor is in the cold condition, all rods are fully inserted Demineralized water shall be recycled to the test

. "$ and Specification 3.3.A is met. tank. Pump minimum flow rate of 50 gpm shall be O verified.against a system head of 2:1,275 psig.

=

Eu$ g 2. Once per 24 months -

'* Manually initiate the system, except the explosive valves. Pump solution through the recirculation ,

path, Amendment No. 446, 105 f

e,_m~..._m . . . - - - . . . - - - - - .-.s m--_. . ,- __.4 - , - _ , -.-, - ,.. . - - . , . . . . . _ - . . . .. _...__~. __ -__ . .. :.___m. - - _. -.______m. --

JAFNPP -.

4.4 (cont'd)

Explode one of three primer assemblies manufactured in the same batch to verify proper function. Then install the two remaining primer assemblies of the same batch in the explosive valves.

Demineralized water shall be injected into the reactor vessel to test that valves (except explosive valves) not checked by the recirculation test are not clogged.

Test trat the setting of the system pressure relief i valves is between 1,400 and 1,490 psig.

3. Once oer 24 months - l Disassemble and inspect one explosive valve so that it can be established that the valve is not clogged.

Both valves shall be inspected within two test intervals.

B. Operation with inoperable Components B. Operation with inonerable Components From and after the date that a redundant component is made When a component becomes inoperable its redundant or found to be inoperable, Specification 3.4.A shall be component shall be verified to be operable immediately considered fulfilled, and continued operation permitted, and daily thereafter.

provided that:

1. The component is returned to an operable condition within 7 days. i Amendment No. 38,131,'48 106

l JAFNPP e 3.4 (cont'd) 4.4 (cont'd) l C. Sodium Pentaborate Solution C. Sodium Pentaborate Solution The standby liquid control solution tank shall contain a boron The availability of the proper boron bearing solution shall be bearing solution with a minimum enrichment of 34.7 atom verified by performance of the following tests:

percent of B-10 that satisfies the volume- concentration requirements of Fig. 3.4-1 at all times when the Standby 1. Once oer month -

l Liquid Control System is required to be operable and the solution temperature including that in the pump suction piping Boron concentration shall be determined. in addition, the shall not be less than the temperature presented in Fig. 3.4-2. boron concentration shall be determined any time water Tank heater and the heat tracing system shall be operable or enriched sodium pentaborate is added or if the solution whenever the SLCS is required in order to maintain solution temperature drops below the limits specified by Figure temperature in accordance with Fig. 3.4-2. If these 3.4-2.

requirements are not met, restore the system to the above limits within eight hours or take action in accordance with 2. Once oer day -

l Specification 3.4.D. I Solution volume and the solution temperature shall be checked.

3. Once oer 18 months -

The temperature and level elements shall be calibrated.

4. Once ner 24 months -

Enrichment of B-10 (in atom percent) shall be checked.

D. If specifications 3.4.A through C are not met, the reactor shall D. Not Used be in at least hot shutdown within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Amendment No.11S,192 107

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

5' s

JAFNPP . .

ATWS requirements are satisfied at all concentrations above The relief valves in the Standby Liquid Control System protect 10 weight percent for a minimum enrichment of 34.7 atom the system piping and positive displacement pumps, whch are -

percent of B-10. nominally designed for 1,500 psig, from overpressure. The pressure relief valves discharge back to the standby liquid Figure 3.4-1 shows the permissible region of operation on a control pump suction line.

sodium pentaborate solution volume versus concentration  :

graph. This curve was developed for 34.7% enriched B-10 B. Operation with inooerable Comoonents and a pumping rate of 50 gpm. Each point on this curve ,

provides a minimum of 660 ppm of equivalent natural boron in Only one of two standby liquid control pumping circuits is I the reactor vessel upon injection of SLC solution. At a needed for operation. If one circuit is inoperable, there is no solution volume of 2200 gallons, a weight concentration of immediate threat to shutdown capability, and reactor operation 13% sodium pentaborate, enriched to 34.7% boron-10 is may continue during repairs. Assurance that the remaining needed to meet shutdown requirements. The maximum system will perform its function is obtained by verifymg pump storage volume of the solution is 4780 gallons which is the operability in the operable circuit at least daily. ,

net overflow volume in the SLC tank. '

C. Sodium Pentaborate Solution Boron concentration, isotopic enrichment of boron-10, solution temperature, and volume are checked on a frequency adequate To guard against precipitation, the solution, including that in  !

to assure a high reliability of operation of the system should it the pump suction piping, is kept at least 10*F above i

ever be required. Experience with pump operability indicates saturation temperature. Figure 3.4-2 shows the saturation  !

that monthly testing is adequate to detect if failures have temperature including 10*F margin as a function of sodium  ;

occurred. pentaborate solution concentration. Tank heater and heat ,

tracing system are provided to assure compliance with this  !

The only practical time to test the Standby Liquid Control requirement. The set points for the automatic actuation of the l System is during a refueling outage and by initiation from local tank heater and heat tracing system are established based on t stations. Components of the system are checked periodically the solution concentration. Temperature and liquid level ,

as described above and make a functional test of the entire alarms for the system annunciate in the control room. Pump  ;

j system on a frequency of more than once every 24 months operability is checked on a frequency to assure a high unnecessary. A test of explosive charges from one reliability of operation of the system should it ever be required.

manufacturing batch is made to assure that the charges are satisfactory. A continuous check of the firing circuit continuity is provided by pilot lights in the control room.

I l

5 I

Amendment No. " ' ' " ' '"

109 j y , , . m- - g +w y4.-- - -- .--, 9.*r- + g -ei- -.c v-eir --- - W - --'- - ---* - - - - - - - - - - ------ - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -'

1 JAFNPP i

l Once the solution is prepared, boron concentration does i not very unless more enriched sodium pentaborate or more water is added. Levelindications and alarms indicate whether the solution volume has changed which might indicate a possible solution concentration change. The test interval has been established considering these factors.

Boron enrichment (B-10 atom percent) does not vary with the addition of enriched sodium pentaborate material or water to the SLC tank provided 34.7% enriched (B-10 g atom percent) is added. Therefore, a check once every 24 months is adequate to ensure proper enrichment.

Amendment No. 444 109a

t 4

ATTACHMENT 11 to JPN-95-051 -

Safety Evaluation For Proposed Changes to Technical Specification Standby Liquid Control System Surveillance Test intervals to i Accommodate 24-Month Operatina Cycles UPTS-95-001N_) ,

i l

l i i i

i 4

l

< 1 i

l l

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

_ _ m . .. __ _ _ __ _. .. _ - _ . . _ . _ _ . _ _ . _ . _ ..

_y i

.,9 Attachment il to'JPN-95-051 i

- Standby Liquid Control System i SAFETY EVALUATION i Page 1 of 10 l

. l. DESCRIPTION OF THE PROPOSED CHANGES

1. Page 105, Specification 4.4.A.1, delete "At least" to make the terminology in this .

j section consistent. This is an' editorial change and does not change the frequency of .l the specification.- The revised specification reads:' j "Once Der month " f

-2. .Page 105 and 106, Specification 4.4.A.2, change the from "during each operating .i cycle" to "per 24 months." The revised specification reads:

"2. Once oer 24 months ,

Manually initiate the system, except the explosive valves. Pump solution  ;

through the recirculation path.

Explode one of three primer assemblies manufactured in the same batch to i verify proper function. Then install the two remaining primer assemblies of the same batch in the explosive valves.

Demineralized water shall be injected into the reactor vessel to test that valves (except explosive valves) not checked by the recirculation test are not clogged.

Test that the setting of the system pressure relief valves is between 1,400 and 1,490 psig."

An editorial change is being made to move the words " pump solution in the recirculation path" from the top of page 106 to the bottom of page 105 to make the specification easier to read. The wording of the specification was changed to clarify the specification. These changes do not change the intent of Specification 4.4.A.2.

' 3. Page 106, Specification 4.4.A.3, add "Once per 24 months" to the beginning of the Specification and change "in the course of two operating cycles" to "within two test intervals." The revised Specification reads:

"3. Once oer 24 months -

. Disassemble and inspect one explosive valve so that it can be established that the valve is not clogged. Both valves shall be inspected within two test intervals."

)

6

i e

Attachment 11 to JPN-95-051  ;

, Standby Liquid Control System SAFETY EVALUATION Page 2 of 10

4. Page 107, Specification 4.4.C.1, delete "At least" to make the terminology in this section consistent. This is an editorial change and does not change the frequency of .

the specification. The revised specification reads: ,

"Once oer month "

5. Page 107, Specification 4.4.C.2, delete "At least" to make the terminology in this section consistent. This is an editorial change and does not change the frequency of the specification. The revised specification reads: ,

"Once oer day "

t

6. Page 107, current Specification 4.4.C.3.a, change "per operating cycle" to "per 18 months." The numbering of the Specification will change to 4.4.C.3 because the ,

current Specification 4.4.C.3.b will be changed as describeo below. The revised  ;

specification reads: 1 i

"3. Once oer 18 months The temperature and level elements shall be calibrated."

7. Page 107, current Specification 4.4.C.3.b, renumber Specification to 4.4.C.4 and revise the Specification to "Once per 24 months." The revised Specification reads:

"4. Once Der 24 months Enrichment of B-10 (in atom percent) shall be checked."

8. Bases page 109, second sentence of the fourth paragraph in the first column, change "each refueling outage" to "every 24 months." The revised text reads:

"Because components in the system are checked periodically as described above, a functional test of the entire system on a frequency of more than once every 24 months  :

is unnecessary."  !

9. Bases page 109a, last sentence of the second paragraph, change "per operating cycle" to "every 24 months." The revised text reads:

l

'"Therefore, a check once every 24 months is adequate to ensure proper enrichment."  ;

I Attachment 11 to JPN-95-051 Standby Liquid Control System SAFETY EVALUATION Page 3 of 10 )

11. PURPOSE OF THE PROPOEED CHANGES This application for amendment to the James A. FitzPatrick Nuclear Power Plant  ;

Technical Specifications proposes to extend the surveillance test intervals for the I Standby Uquid Control (SLC) System to accommodate 24 month operating cycles.

These changes will eliminate the need to shut the plant down mid-cycle to conduct l these surveillances. Extended surveillance intervals are identified in the proposed ,

Technical Specifications as being performed "once per 24 months." SLC system temperature and level instrument calibrations, currently performed "at least once per operating cycle," are identified as performed "once per 18 months." These changes follow the guidance provided by Generic Letter 91-04 (Reference 1).

SLC system surveillance tests conducted once per operating cycle were evaluated to confirm that the surveillance frequencies could be safely extended. The evaluation (Reference 2) included a detailed study of SLC system surveillance history and operational occurrences. Surveillance test data was analyzed, where applicable, for components affected by the extended operating cycle. The evaluation concluded that all SLC surveillance tests can be safely extended to accommodate a 24 month operating cycle except the SLC system temperature and level instrument calibrations that will remain on an 18 month frequency.

SlaDdby Liquid ControLSystem Qbiective and Description The design objective of the SLC system is to provide a backup method, independent of the control rods, to bring and maintain the reactor subcritical from the most reactive condition as the reactor cools. The system would be used in the unlikely event that a sufficient number of control rods could not be inserted into the core to accomplish reactor shutdown in the normal manner. The system is sized to counteract the positive reactivity effect from a full power to a cold shutdown condition, at any time in core life, by the injection of high pressure borated water into the reactor vessel.

The SLC system consists of a tank of neutron absorber solution (soaium pentaborate),

two 100% capacity positive displacement pumps, two explosive actuated injection valves, a test water tank, and associated local valves and controls mounted in the reactor building outside the primary containment. The injection point for the SLC system is a standpipe located in the lower plenum of the reactor pressure vessel. The system is remote manually initiated from the control room. The SLC system satisfies the requirements of the Anticipated Transient Without Scram (ATWS) Rule (10 CFR 50.62(c)(4)).

The SLC system, with the exception of the injection valves and associated downstream piping, is designed to allow testing of major components during reactor operation.

Once per month, demineralized water is recycled to the test tank to demonstrate operability of the SLC system pumps and valves. The only practical time to test the injection portion of the system, and to perform functional testing of the system by manual initiation, is during refueling outages. This precludes inadvertent injection of borated water into the reactor coolant system during plant operation. Since the major

. - - - . - .- ~- -

1 Attachment 11 to JPN-95-051 Standby Uquid Control System SAFETY EVALUATION

' Page 4 of 10

system components are checked on a monthly basis, functional testing of the entire ,

SLC system on a frequency of more than once per operating cycle is not necessary.  !

l The availability of proper boron bearing solution is verified periodically.- The solution i temperature and volume is checked once per day. Boron concentration is determined I once per month, any time water or enriched sodium pentaborate solution is added, or if the solution temperature drops below Technical Specification limits._ Storage tank and  ;

pump suction piping heat trace instrumentation are currrently calibrated, and the B-10 ,

enrichment (in atom %) is checked, once per operating cycle. l lil. SAi"ETY IMPLICATION OF THE PROPOSED CHANGES Once per operating cycle surveillance requirements (SRs) for the SLC system are provided in Technical Specifications 4.4.A.2, 4.4.A.3,4.4.C.3.a and 4.4.C.3.b. .

Surveillance requirement 4.4.A.2 includes four component operability checks. The purpose of these tests and the potential safety implications of the extended  !

surveillance interval are discussed below. ,

Surveillance Reauirement 4.4.A.2 This Surveillance requires that the following once per cycle testing be performed on  ;

the SLC system to verify operability: ,

1. Manually Initiate the system, except for the explosive valves, and pump solution  ;

in the recirculation path.

During the performance of this test, each SLC pump is operated to pump solution from i the SLC storage tank through the test line and back into the storage tank. This test i verifies that the piping between the SLC storage tank and the pump inlets is not blocked. A potential source of blockage is the precipitation of sodium pentaborate in  ;

the tank and suction piping. This is avoided by maintaining temperature of the tank  ;

and suction piping at least 10 F above saturation temperature for the concentration of the solution by use of tank heaters and heat tracing on the pump suction lines. These heating systems, along with Technical Specification required daily checks of tank j temperature, ensure that sodium pentaborater remains in solution and does not result in j blockage of the flowpath in addition, a review of surveillance test results from 1983 to 1995 shows no failures. ]

i t

i i

i

O-Attachment ll to JPN-95-051 Standby Uquid Control System SAFETY EVALUATION Page 5 of 10

2. Explode one of three primer assemblies manufactured in the same batch to verify proper function. Then install the two remaining primer assemblies of the same batch in the explosive valves.

The purpose of this test is to establish that the valve explosive charge will function properly. The system utilizes two squib activated shear explosive valves in parallel as a means of isolating both pumps from the reactor vessel. The valves are maintained in the closed position and are activated only in an emergency to provide a flow path to the reactor vessel. The firing circuit continuity for each valve is continuously monitored by pilot lights, ammeters, and an annunciator signaling loss of continuity in the control room to alert plant control room operators of any problems with the circuit. The proposed testing interval of 24 months (+25%) is within the manufacturers recommended service life for the explosive charges. Evaluation or surveillance test results from 1983 to 1995 show no test failures.

During the 1992 performance of this surveillance, the testing was stopped because it was noticed that the squib valve continuity circuit was not functioning properly. Upon investigation, several electronic components were found to be defective. The test was concluded following repair of these components and the explosive charges functioned properly. Further investigation into the cause of these component failures led to '

implementation of a modification to install surge suppression varistors to protect the squib valve continuity circuit electronics. These failures do not preclude extension of this surveillance interval because the failed components are outside the scope of this surveillance requirement and would not have prevented the squib valves from operating.

3. Demineralized water shall be injected into the reactor to test that valves (except explosive valves) not checked by the recirculation test are not clogged.

The SLC system is remote manually initiated from the main control room to demonstrate the capability of the SLC system to inject demineralized water into the reactor vessel. The firing of the explosive valves is simulated and the system pumps and valves are flushed with demineralized water prior to the test to preclude entry of sodium pentaborate solution into the reactor vessel. The pumps and valves in the flow path, up to the injection valves, are tested monthly. The only practical time to test the injection portion of the system is during plant shutdown for refueling. Evaluation of surveillance test results from 1983 to 1995 has identified no test failures.

4. Test that the setting of the system pressure relief valves is between 1400 and 1490 psig.

This test demonstrates that the SLC pump discharge safety valves lift between 1400 and 1490 psig. These valves protect the system from overpressure. The valves are only used and pressurized during brief periods for system testing. Therefore, the possibility of valve degradation is very low. The SLC system is designed with two

Attachment ll to JPN-95-051 Standby Uquid Control System SAFETY EVALUATION Page 6 of 10 redundant loops. If one relief valve lifted at too low a pressure, the check valve in that discharge line would prevent the other pump flow from recycling back to the storage tank. Relief valve failure due to setpoint drift in the low direction would be detected during monthly and quarter 1y pump testing. The proposed 24 month testing frequency

!s more frequent than the American Society of Mechanical Engineers (ASME)Section XI testing requirements for relief valves. The current edition of the ASME code for the FitzPatrick Plant (1980 Edition through 1981 Winter Addenda) requires testing of this type of valve at five year intervals. Surveillance test results from 1983 to 1995 identified no test failures.

Conclusion SR 4.4.A.2 Based on a review of past surveillance history, on-line testing performed on major SLC system components, and engineering evaluation that the longer operating cycle length will not increase the probability of test failure, extension of this surveillance requirement to support a 24-month operating cycle is acceptable. ,

Surveillance Reauirement 4.4.A 3 This surveillance requires disassembly and inspection of the intemals of one explosive valve so that it can be established that the valve is not clogged. Both valves are inspected in the course of two operating cycles. The valves are normally in a standby condition and are not operated except to provide a flowpath for borated water into the reactor vessel or for testing on a refueling outage basis. Due to the limited use of the valves, they are not likely to wear out due to fatigue. Therefore, the operating cycle length does not have a significant impact on maintenance requirements. An evaluation of surveillance test data from 1990 to 1995 indicates that the test results have always been within the acceptance criteria.

Conclusion SR 4.4.A.3 Based on past surveillance history and the limited use of these valves, extending this test to a 24 month interval will not significantly increase the probability of test failure.

SumeillauseEgguirement 4.4.C.3 (Current Specification 4.4.C.3.a)

This surveillance requires that the temperature and level elements associated with the sodium pentaborate storage tank and pump suction piping be calibrated once per operating cycle. The solution is maintained at least 10 F above the solution saturation temperature by a tank heater and a piping heat tracing system. This prevents the precipitation of sodium pentaborate in the storage tank and pump suction lines.

Temperature indication and alarms for the system annunciate in the control room.

Temperature is checked daily and provides assurance that the system is maintained as required by Technical Specifications. Level instrumentation is provided for the sodium pentaborate storage tank. Monitoring of tank level, along with level alarms, are used to detect whether the solution volume has changed, which may be indicative of a solution concentration change. Tank level is checked daily, as required by Technical

l I

a Attachment il to JPN-95-051 Standby Liquid Control System

, SAFETY EVALUATION Page 7 of 10 Specifications, using two independent means. These daily checks will detect  !

instrument drift or level changes due to water addition, water evaporation, or system leaks.  !

i An evaluation of past calibration data for the temperature instrumentation does not support extension of the calibration frequency to support a 24 month operating cycle. l Based on operating history, temperature instrumentation drift will most likely result in '

i alarms. Further investigation of these alarms will reveal the need for instrument 3

calibrations. Temperature instrumentation is capable of being calibrated while the unit is at power. As such, the calibration frequency of 18 months is not cycle length or refueling outage dependant. Therefore, keeping this calibration on an 18 month

. frequency will not be a burden on plant operation or plant personnel.

An evaluation of past calibration data for the sodium pentaborate tank level instrumentation does not support extension of the calibration frequency to support a 24 month operating cycle. Based on past operating history, level instrument drift problems will most likely result in alarms which will alert plant personnel to verify the actual tank level. The level instruments are capable of being calibrated while the unit is at power. As such, the calibration frequency of 18 months is not cycle length or refueling outage dependent. Therefore, keeping the level calibration on an 18 month frequency will not be a burden on plant operation or plant personnel.

Conclusion SR 4.4.C.3 Based on the discussion above, the temperature and level calibration required by Specification 4.4.C.3 shall remain on an 18 month frequency.

l TechnicaLSpecification . Surveillance 4.4.c.4 (current soecification 4.4.c.3.b)

This surveillance requires that the enrichment of the B-10 (in atom percent) in the sodium pentaborate solution be checked once per operating cycle. The minimum enrichment is 34.7 atom percent of B-10. The SLC boron concentration is checked by chemical analysis monthly, any time water or enriched sodium pentaborate is added, or if the solution temperature drops below Technical Specification limits. Once the solution is prepared in the tank, the concentration of boron will not lower unless more boron or water is added. Level indications and alarms are used to detect whether the solution volume has changed, which might be indicative of a solution concentration change. Boron enrichment in atom % will not vary with the addition of enriched sodium pentaborate material or water to the SLC tank provided that 34.7% enriched (B-10 Atom %) is added. Therefore, the check of boron enrichment in atom % is not affected by the longer operating cycle.

' Conclusion SR 4.4.C.4 Based on the above information, the once per operating cycle check of boron enrichment in atom % can safely be extended to support a 24 month operating cycle.

_ _ . - _ _ _ _ _ _ . _ ._ _ . _ _ . _ _ _ _ _ _ _ . ._ _ , ~ . ._ _ _ . _

i r

Attachment 11 to JPN-95-051 Standby Uguid Control System

- SAFETY EVALUATION ,

. Page 8 of 10 ATWS Rule (10 CFR 50.62(cV4)) Commitments The commitments regarding conformance of the SLC system to the ATWS rule were ,

reviewed to ensure the increased surveillance interval of 24 months would not  :

invalidate those commitments. The ATWS rule requires that the SLC system have a ,

minimum equivalent control capacity of 86 gallons per minute (gpm) of 13 weight ,

percent sodium pentaborate solution. This equivalent control capacity is met by l' increasing boron-10 enrichment to 34.7 atom percent and taking credit for a 50 gpm pumping capacity of the SLC pumps. The final in-vessel boron concentration following injection of SLC solution was increased from 600 ppm of natural boron to 660 ppm of  ;

equivalent natural boron. This additional margin was used to permit increases in core j reload enrichment and energy content in future reload core designs. .

The proposed changes to Technical Specifications do not change the commitments related to the minimum equivalent control capacity of the SLC system because boron- l 10 enrichment will continue to be maintained at the minimum required enrichment.

The capacity of the SLC pumps is verified once per month to be 2. 50 ppm, therefore this commitment is not affected by the longer operating cycle. The affect of the longer operating cycle on the 660 ppm acceptance criteria has been evaluated by General  !

Electric. The evaluation shows that 660 ppm is adequate to shutdown the reactor for an equilibrium, uprated core loaded for a 24 month cycle (Reference 2). Therefore, the -  !

proposed increase in surveillance frequency will not adversely affect the final in-vessel I boron concentration following injection of the SLC solution.

l IV. EVALUATION _QE_tiO SIGNIFICAM  !

Operation of the FitzPatrick plant in accordance with the proposed Amendment would l not involve a significant hazards consideration as defined in 10 CFR 50.92 since it ,

would not. j 1

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

The proposed changes do not involve any physical changes to the plant, do not alter any SLC system functions, and will not degrade the performance of the SLC system.

The type of testing and the corrective actions required if the subject SLC surveillances fail remain the same. The proposed changes do not adversely affect the availability of the SLC system or the ability of the system to bring the reactor from full power to'a

. cold shutdown condition in the unlikely event that control rods cannot be inserted. A i historical review of SLC surveillance test results indicated that there was no evidence I of any failures that would invalidate the above conclusions.

l i

..egw ~ ~ , - - , . , . -y . - -- --r- w,

l o

i  !

Attachment ll to JPN-95-051

Standby Uquid Control System i d

i

~

' SAFETY EVALUATION Page 9 of 10 - l t

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

evaluated. l 1

The proposed changes'do not introduce any failure mechanisms of a different type  !

than those previously evaluated since there are no physical changes being made to ,

the facility. No changes are proposed to the type and method of testing performed, j only to the length of the surveillance interval. Past equipment performance and on-line ,  ;

i 1

testing indicate the longer test intervals will not degrade SLC equipment. A historical j review of surveillance test results indicated that there was no evidence of any failures l that would invalidate the above conclusions. l 7

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

i Although the proposed changes will result in an increase in the interval between I surveillance tests, the impact on system reliability is minimal. This. is based on more  ;

frequent on-line testing of major system components and the redundant design of the j j SLC system. A review of past SLC surveillance history has shown no evidence of j failures that would significantly impact the reliability of the SLC system. The longer ,

! testing intervals do not significantly impact the SLC safety margins for SLC norma! .

i' operation, operation with inoperable components,' or sodium pentaborate solution as l j' . described in the bases of the Tr chnical Specifications. Operation of the plant remains unchanged by the proposed SLC surveillance interval extensions. The assumptions in the Plant Ucensing Basis are not impacted. Therefore, the proposed changes do not result in a significant reduction in the margin of safety.

i- V. IMP _LEMENTATION 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 j environment.

i

j. VI. CONCLUSION Based on the discussions above, the SLC surveillance tests in Specifications 4.4.A.2, a 4.4.A.3, and 4.4.C.4 can be safely extended to accommodate a 24 month operating cycle. However, the SLC system temperature and level instrument calibration i requirements of Specification 4.4.C.3 will remain on an 18 month frequency.

i 1 4

. The assumptions in the Fitzpatrick licensing basis are not invalidated by performing the j SLC surveillances at the bounding interval limits (30 months) to accommodate the 24  ;

i month operating cycle. The extended operating cycle does not adversely affect the j commitments regarding conformance with the ATWS rule. l

! I i

. 4 a - . _ . . . - . . - - - , ..- . -

,,l

6 Attachment 11 to JPN-95-051 Standby Uquid Control System SAFETY EVALUATION Page 10 of 10 The Plant Operating Review Committee (PORC) and the Safety Review Committee (SRC) have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve an unreviewed safety question, or a significant hazards consideration, and will not endanger the health and safety of the public.

Vll. REFERENCES

1. Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate 24-Month Fuel Cycle," dated April 2,1991. <,

2. NYPA Report No. JAF-RPT-SLC-00336 Revision 2, " Standby Uquid Control (SLC)

' Surveillance Extensions," dated November 16,1995.

- 0 ATTACHMENT lll to JPN-95-051 Markup of the current Technical Spec?ification ptges Extension of Standby Liquid Control System Surveillance Test intervals 19 Accommodate 24-Month Operatina Cycles WPTS-95-001H) - ,

4 t

4 k

i 4

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

l

JAtCPP 3.4 lit!IIING COceplILpMS_ LOREER_AT19q 4.4 SURVElt.fANCE. REQUJRD4ENTS 3.4 STANDRI_. LIQUID CONTROL SYSTE!! 4.4 ST_ANDBY _LJOUID_COttTRO_f, SYSTEM Apolicability:

A_pplisab_i Hty: .

Applies to the operating status of the Standby Liquid Applies to the periodic testing requirements for the Control System.

Standby Liquid Control System.

Obiectiver Qbjgs.tive To assure the availability of a system with the capability to shut,down the reactor and malatala the To verify the operability of the Standby Liquid Control System.

shutdown condition without control rods. ,

Spec 111 cations specifIceting:

A. Normal Operatloa A.

, Normal Goeration During periods whom fuel is la the reactor and Prior to startup from a cold condition, the The operability of the Standby Liquid Control System 1 l

Standby Ligold Control System shall be operable shall be verified by performance of the following j test :

except as specified la 3.4.8 below. This system l need not be operable when the reactor is la the 1. less 23cmgetmonth-cold condities, all rods are fully inserted and Specification 3.3.A is met.

Domineralised water shall be recycled to the test tank. Pump minimum flow rate of 50 gym

• shall be verified agalast a system head of 2 l 1,275 psig. '

l Pe .2 4 th oMk .1 -

2. M h nach operatlag cy W i Manually laitiate the system, except the  !

eEplosIVe valves, 9 ,

A r o a c c.;l .L4, w p.Ar, . -

L Amendment No. I16 105

. . _ . - . . _ _ _ _ . _ _ _ . _ - _ _ _ _ - . _ _ ___ _ _ _ _ ___c-_ - - - - - - - . -

• JAFNPP tw o vt. M bo M oC pq lOY 4.4 (cont'd)

?

[ pump solution in the recirculationM Explode one of three primer assemblies rnanufactured in same batch to verify proper function. Then install the two remaining primer assemblies of the same batch in the explosive valves.

Demineralized water shall be injected into the reactor vessel to test that valves (except explosive valves) not checked by the recirculation test are not clogged.

Test that the setting of the system pressure relief valves is ouee. par 2l mah " - between 1,400 and 1,490 psig.

3. Disassemble and inspect one explosive valve so that it can be established that the valve is not clogged. Both valves shall be inspectectTn the course of two operam y cy6.3 u . A,a L o 4=.st es ke val.s .

B. Operation with inoperable Components B. Operation with inoperable Components i

When a component becomes inoperable its redundant From and after the date that a redundant component is made or component shall be verified to be operable immediately and i found to be inoperable, Specification 3.4.A shall be considered g daily thereafter.

fulfilled, and continued operation permitted, provided that:

1. The component is returned to an operable condition within 7 days.

l

(

Amendment No. 36,}24 148 106

l .

l l

~

JAFNPP 3.4 (Cont'd) 4.4 (Cont'd)

C. Sodnarn Pentaborate Solution C. Sodnan Pentaborate Solution The standby hqual control solution tank shen contain a baron The availability of the proper boron bearing solution shen be bearing solution with a minimum ennchment of 34.7 atom verified by performance of the following tests:

percent of B-10 that satisfies the volume-concentration requirements of Fig. 3.4-1 at aN times when the Standby 1.

Liquid Control System is required to be operable and the solution temperature including that in the pump suction pgang [hdnce Baron concentration nershen month be determmed. - In addition, the shou not be less then the temperature presented in Fig. 3.4-2. boron concentration shen be determmed any time water Tank heater and the host tracing system shen be operable or enriched sodeum pontaborate is added or if the solution whenever the SLCS is required in order to mentain solution temperature drops below the limits specified by temperature in accordance wi*h Fig. 3.4-2. If these Fig. 3.4-2.

requirements are not met, restore the system to the above  ;

limits within eight hours or take action in accordance with 2. At tnce ner day -

Specification 3.4.D. '

Solution volume and the solution temperature shen be checked.  !

/t mao}Ls l 3. At8-==~ dhce nerbatina cvc--

~

l l

The temperature and level elements shall be l cabbrated.

<( , on. par .2 <f m ods -

Ennchment of B-10 On atom percent) shaN be checked.  :

D. If specifications 3.4.A through C are not met, the reactor shall D. Not Used l i l be in at least hot shutdown within the followmg 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

l l Amendment No.1/8 ,192 107 l

JAFNPP ATWS requirements are satisfied at all concentrations above 10 The relief valves in the Standby Liquid Control System protect weight percent for a minimum enrichment of 34.7 atom percent the system piping and positive displacement pumps, which are of B 10.

nommally designed for 1,500 psig, from overpressure. The Figwe 3.4-1 shows the permissible region of operation on a Pmsswe W @es dhge M to the standby hquid sodium pernaborate solution volume versus concentration codd pump Mon kne.

graph. This curve was developed for 34.7% enriched B-10 and B. Operation with inoperable Components a pumpeg rate of 50 gpm. Each pont on this curve provides a mmimum of 660 ppm of equivalent netwal boron m the reactor Only one of two standby hquid control pumping circuits is up n infection d E wm At a h dune d fw if M is @ % h h m 2200 gallons, a weight concentration of 13 % sodium immediate threat to shutdown capabehty, and reactor operation perdimborate, ennched to 34.7% boron-10 is needed to meet g ing rp. Assmance M h rm shutdown requirements. The manomum storage volume of the systwn M Wonn Rs W is N h %% m solution is 4780 gallons which is the not overflow volume in the pw , the opwah W at W @

in SLC tank. C. Sodium Pentaborate Soluton Boron concentration, isotopic enrichment of boron-10, solution To guard agamst precipstation, the solution, meludmg that in the temperature, and volume are checked on a frequency pump suction piping, is kept at least 10*F above saturation adequate to assure a high rehability of operation of the symem temperature. Figure 3.4-2 shows the saturation temperature should it every be required. Exponence with pump operabihty includog 10'F margin as a function of sodium pentaborate mdicates that monthly testing is ar*wyda to detect if failures solution concentration. Tank heater and heat tracing system have occurred.

are provided to assure compliance with this requirement. The The only practical time to test the Standby Uquid Control set pnts fw h womak em d h M Mw W System is during a refueling outage and by initiation from local heat tracmg systwn am established W on the solution stations. Components of the system are checked periodically concenkafon. Tanpwatwe W W W h tw h as desenbed above and make a functional test of the entire systwn Mate in h conM mom. W operaWy is system on a frequency of more than h refuelina-'3 n a kequency to asswe a @ rMty d opwats unnecessary. A test of explosive ges from one of the system should it ever be required.

manufacturing batch is made to assure that t is charges are satisfactory. A continuous check of the firing c rcuit continuity is provided by pilot lights in the control room.

"ug.29mu%s Amendment No. ;MI, Mt$ 148 109

._ m. ... . _ . . . _ .- . ._ _ _ . . . .-.. . . . _ . - - . . - . . . _ . - . -

jab. P 3

Once the solution is prepared, boron concentration does not vary, unless more enriched sodiume pente-borate or more water is added. Level ladications and alarms indicate whether the solution volwee has changed which might indicate a possible solutlos concentration change. The test interval .

has been established considering these factors.

Boroa enrichment (B-10 stem percent) does not very with the addittom of enriched sodium pentaborate meterial or water to the Elf tank provided 34.7% enriched (B-10 atos percent) is added. Therefore, a check once r opo C -

e 1. t. t. .a..r. ..r.

. - .t. h

.r.s e,r] [7R r4 W O 5 i

6 Amendment No. I16 '

109a

_ _ . -_ , . _