ML20111B448
| ML20111B448 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/22/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20111B439 | List: |
| References | |
| NUDOCS 8503130114 | |
| Download: ML20111B448 (6) | |
Text
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,f(gp urugk UNITED STATES yj g
NUCLEAR REGULATORY COMMISSION E
- j WASHINGTON, D. C. 20555 (v/
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 87 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 Backaround and Discussion By letters JPN 84-81 dated December 6, 1984, JPN-85-01 dated January 10, 1985, and JPN-85-11 dated February 14, 1985, the licensee (Power Authority of the State of New York) requested changes to the James A. FitzPatrick Nuclear Power Plant Technical Specifications (TS) to allow refueling with the reactor protection system (RPS), and certain specified refueling interlocks and rod blocks inoperable. The licensee has stated that these changes are necessary to allow installation of Analog Transmitter Trip S components without causing excessive delays (up to 20 days) ystem (ATTS) during the refuelin~g outage. The ATTS is a solid-state electronic trip system being installed to replace existing mechanical sensing devices (e.g., pressure switches and differential pressure switches) for the RPS, nuclear steam supply shutoff system (NSSSS), emergency core cooling system (ECCS), and reactor core isolation cooling (RCIC) system. Advantages of the ATTS over the existing mechanical trip system components include continuous indication of measured parameters, reduced setpoint drifit, reduced time required for 1
testing, and the prevention of instrument valving errors during instrument functional tests.
The proposed TS changr3 will allow refueling operations and installation of ATTS components to be performed and managed simultaneously, and will allow installation of ATTS components in redundant protection system channels simultaneously. With the RPS required to be operable, ATTS modifications would be restricted to one channel at a time while that channel was in the tripped condition, thus, placing the unit in a half-scram configuration.
The specific TS chances are to Table 3.1-1 " Reactor Protection System (SCRAM) Instrumentation Requirements," allowing the RPS to be inoperable when in the Refuel Mode if all control rods are fully inserted into the core and electrically disarmed (described below), and Section 3.10.A " Refueling Interlocks," allowing refueling interlocks and rod blocks associated with single rod motion permissives to be inoperable if all control rods are fully inserted and electrically disarmed.
The staff's review has concluded that the proposed changes to the Fit: Patrick TS requested by the licensee are acceptable as discussed in the evaluation provided below.
It should be noted that the ATTS, designed by General B503130114 850222 PDR ADOCK 05000333 P
Electric (GE), has been retrofitted to several operati reactors BWRs).
has been r(eviewed and accepted by the staffA GE Topical R ng boiling water the ATTS installed, the licensee should reference thPrior to plant operatio differences between the FitzPatrick ATTS design and the GE report, ide and address propose modifications (e.g.d technical specification changes resulting from the e GE standard design,
, performance of channel checks each shift).
2.0 Evaluation The reactor protection system (RPS) is designed to aut insertion of all control rods into the core (i e omatically initiate monitored variables exceed pre-established limits to prot.., scram the onset and consequences of conditions that threaten the int ect against the fuel cladding and reactor coolant pressure boundegrity of the initiates a reactor scram on the following signals is Instrumentation that ary.
when in the refuel mode to prevent or terminate inadverte trequired Mode Switch in Shutdown criticality.
n Manual Scram Intermediate Range Monitor (IRM) Trips Average Power Range Monitor (APRM) Trips Scram Discharge Volume High Water Level l
Other scram functions are required to be operable i l
not diminish the protection provided by the RPSensure tha w r operation does The proposed TS changes will allow the RPS to be in mode if all rods are fully inserted and electrically disoperable in the refu
" electrically disarmed control rod" is defined in th follows:
armed. An e Fitzpatrick TS as "To disam a rod drive electrically, the four amphen l t connectors are removed from the drive insert and withd o
ype plug rendering the rod incapable of withdrawal disarming does not eliminate position indication " equ a solenoids Electrical Thus, for each control rod, four amphenol connecto the four associated directional control valve DCV) rs (one f disconnected, preventing solenoids will be preventino DCV operation. power from being applied to the solenoids, thus, With the rods fully inserted and the DCVs disabled (i.e., closed with power removed) withdrawal motion. locking mechanism can not be unlocked / disengaged and 123) are located at the individual hydraulic controlThe amp each rod.
, 121, 122, The licensee has stated that once disconnectedunits (HCD be tagged out of service with red "00 NOT OPERATE" t
, the cables will ags in accordance with
procedures and administrative controls which meet the requirements of 10 CFR 50 Appendix B.
When in the refuel mode, neutron monitoring system (NMS) instrumentation indications and alarms are required to be operable and periodically checked in accordance with Sections 3.10 and 4.10 (Limiting Conditions for Operation, and Surveillance Requirements for Core Alterations) of the FitzPatrP:k TS. This includes daily verification of source range monitor (SRM) operability.
In addition, the licensee will perform daily verification of control rod position. The staff has concluded that this combination of daily surveillance and operability of NMS alarms is sufficient to verify subcriticality with the RPS inoperable during refueling.
The licensee has stated that the nuclear characteristics of the core assure that the reactor would remain subcritical even if the highest worth control rod were fully withdrawn.
1 The proposed TS changes will also allow control rod blocks and refueling 4
interlocks associated with rod withdrawal permissives to be inoperable
'i during refueling. The purpose of the control rod blocks and refueling interlocks during refueling are to prevent inadvertent criticality by restricting the movement of control rods. With the control rods fully inserted and electrically disarmed, a rod drop accident is not considered credible ^ since it can not occur in the absence of rod withdrawal. The only other design basis accidents applicable during refueling are fuel assembly drop accidents. The proposed revisions will not increase the probability of a fuel assembly drop accident.
Furthermore, neither the RPS nor the control rod blocks and refueling interlocks are designed to prevent or mitigate the consequences of this type of accident. All refueling interlocks not based on control rod position will remain operable.' It would not be possible to verify operability of rod blocks and refueling interlocks using rod position as an input with the rods electrically disarmed since rod movement is not possible. The staff has concluded that the proposed TS changes are acceptable since rod movement is not possible, and rod position and core conditions are checked periodically. The licensee has stated that all tests performed as part of the refueling outage that require control rod movement will be performed following restoration of the RPS, control rod blocks, and refueling interlocks to an operable status.
While in the refuel mode with the RPS inoperable, maintenance activities associated with the control rod drive mechanisms (CRDMs) is prohibited. The control rod assemblies are to remain coupled to the CRDMs. The licensee has stated that there will be no activities performed involving the control rod assemblies or drive mechanisms during refuelino with the RPS inoperable.
In addition, the licensee has stated that at least one train of the standby liquid ~ control system (SLCS) will remain operable at all times during refueling with the RPS inoperable. This will provide the licensee with the capability to inject liquid neutron poison into the reactor vessel if necessary.
It is noted that the control rod drive hydraulic system and manual scram circuits will remain operable.
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. Based on the above evaluation, we have determined that the proposed revisions to the FitzPatrick TS allowing refueling with the RPS and certain specified control rod blocks and refueling interlocks inoperable are acceptable.
3.0 Emerr!ency Circumstances The FitzPatrick facility shut down for a refueling outage on February 16, 1985.
By letter dated February 21, 1985, the licensee infonned us that the duration of the outage has been shortened by approximately 5 days because the scheduled completion time for a critical path modification (the l
installation of valve 10MOV-18 in the RHR system) has been reduced.
Additionally, the commencement of refueling operations has been advanced because preparations (vessel disassembly, cavity flood-up, and achievement of satisfactory water qualityl have been completed earlier than scheduled and normally a'nticipated. A delay in issuance of this amendment will preclude simultaneous installation of ATTS components and refueling, resulting in the outage being extended.
4.0 Final No Sianificant Hazards Consideration Determination 4.1 State Consultation In accordance with the Commission's regulations, consultation was held with the State of New York by telephone. The State expressed no concern over issuance of this amendment from the standpoint of no significant hazards consideration determination.
4.2 Response to Comments In response to the FEDERAL REGISTER Notice of February 4, 1985 (50 FR 4929) containing the NRC proposed no significant hazards consideration determination, no comments were received.
4.3 No Significant Hazards Consideration Determination The Commission's regulations in 10 CFR 50.92 state that the Connission may make a final determination that a license amendment involves no significant hazards considerations if operation of the facility in accordance with the amendment would not:
(1)
Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or
(3)
Involve a significant reduction in a margin of safety.
The information in this SE provides the basis for evaluating this license amendment against these criteria.
Since the reactor would be in cold shutdown, the only design basis accidents that could possibly occur, and, therefore, need to be considered are: a rod drop accident, a fuel assembly drop accident in the spent fuel pool, and a refueling accident in which a fuel assembly drops on the core during refueling. The revisions contained in the amendment would not increase the probability of fuel assembly drops.
In the unlikely event one occurs, neither the reactor protection system nor the control rod blocks and refueling interlocks could, or are designed to, prevent or mitigate the consequences. A rod drop accident, which is described in Section 14.6.1.2 of the FitzPatrick Final Safety Analysis Report (FSAR), is not considered 4
credible since it cannot occur in the absence of rod withdrawal. Rod motion is physically prevented by. electrically disarming all reds as l
described above.
In addition, procedures and administrative controls which meet the requirements of 10 CFR 50 Appendix B will be used to assure that the rods are electrically disarmed. On this basis, the amendment would not involve a significant increase in the probability or consequences of an accident,previously evaluated.
The amendment, in addition, would not create the possibility of a new or different kind of accident from any accident previously evaluated. The only events that could be associated with the revisions contained in the amendment have been discussed above. No new possible events can be attributed to these revisions contained in the amendment. Since the revisions apply only when all rods are fullyinserted and electrically disarmed, the reactor, in effect, would already be in a scrammed condition. Therefore, under these circumstances, no reduction in safety nargin would result from an inoperable RPS.
In addition, the nuclear I
characteristics of the core assure that the reactor would remain subcritical even if the highest worth control rod were able to be fully withdrawn. Thus, this amendment does not involve a significant reduction in a margin of safety.
Accordingly, we conclude that the amendment to Facility Operating License No. DPR-59, which permits refueling operations to proceed with the Reactor Protection System inoperable, involves no significant hazards j
consideration.
j S.0. Environmental Consideration i
i This amendment involves a change in the _ installation or use of a facility I
i component located within the restricted area as defined in 10 CFR Part 20.
The 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 l
I
l,
i individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding. The Commission has~ also made final no significant hazards 4
consideration finding with respect to this amendment. Accordingly, this amendment meets-the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment, s
6.0 Conclusions We have concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the proposed manner, and (2) public such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
j Principal Contributor:
R. Kendall Dated:
February 22, 1985 t
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