ML20118B650
| ML20118B650 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/25/1992 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20118B648 | List: |
| References | |
| NUDOCS 9210060258 | |
| Download: ML20118B650 (11) | |
Text
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ATTACHMENT I to JPN 92-058 PROPOSED TECHNICAL SPECIFICATION CHANGES PRIMARY CONTAINMENT IODINE MONITORING SPECIF_ICATIONS (JPTS-91-006) l l
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 l-9210060258 920925 PDR ADOCK 05000333 P
JAFNPP 3.6 4.6 BASES (cont'd) leakage were also considered in establishing the limits. The The capacity of the dryweu sump pumps is 100 gpm, and the behavior of cracksin piping systems has been experimentally and capacity of the drywell equipment drain tank numps is ciso 100 analybeallyinvestigated as part of the USAEC-sponsored Reactor gpm. Removal of 50 gpm from either of these sumps can be.
Primary Cooiant System Rupture Study (the Pipe Rupture Study).
accomplished with considerable margin.
Work utilizing the data obtained in this study indicates that leakage from a crack can be detected before the crack grows to The performance of the Reactor Cuolant Leakage Detection a dangerous or critical size by mechanically or thermally induced System will be evaluated during the first 5 yr of plant operation, cyclic loading, or stress corrosion cracking or some other and the conclusions of this evaluation will be reported to the mechanism characterized by gradual crack growth.
This NRC.
evidence suggests that for leakage somewhat greater than the limit specified for unidentified leakage, the probability is small it is estimated that the main steam line tunnelleakage detectors that imperfections or cracks associated with such leakage would are capable of detecting a leak on the order of 3,500 Ib/hr. The grow rapidly.
However, the establishment of allowable systern performance will be evaluated during the first 5 yr of unidentified leakage greater than that given in 3.6.D on the basis plant r >eration, and the conclusions of the evaluation will be of the data presently available wou!d be premature because of reported to the NRC.
uncertainties associated with the data. For leakage of the order of 5 gpm as specified in 3.6.D, the experimental and analytical The reactor coolant leakage detection systems consist of the data suggest a reasonable margin of safety such that leakage of drywell sump monitoring system and the drywell continuous this magnitude would not result from a crack approaching the atmosphere monitoring system.
The drywell continuous critical size for rapid propagation.
Leakage less than the atmosphere monitoring system utilizes a two-channel monitor to 1
magnitude specified can be detected reasonably in a matter of a provide information on particulate and noble gas activities in the few hours utilizing the available leakage detection schemes, and drywell atmosphere. Two independent and redundant systems if the origin cannot be determined in a reasonably short time, the are provided to perform this function. This system supplements Plant should be shut down to allow further investigation and the drywell sump monitoring system in detecting abnormal corrective action.
leakage that could occur from the reactor coolant system. In the event that the drywe!! continuous atmosphere monitoring system is inoperable, grab sample will be taken on a periodic basis to monitor drywell activity.
Amendment No.
151
O JAFNPP TABLE 4.6-2 Minimum Test and Calibration Freauency for Drvwell Continuous Atmosobere Radioactivity Monitorino System Inst. Channel Inst. Functional Test Calibration Sensor Check 1.
Air Particle Analyzer None Once / 3 mos.
Once / day 2.
Gaseous Activity Analyzer None Once / 3 mos.
once / day I
Amendment No.
162a
Attachm:nt 11 to JPN-92 058 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES PRIMARY CONTAINMENT IODINE MONITOnlNG SPECIFICATIONS (JPTS-91-006) 1.
DESCRIPTION OF THE PROPOSED CHANGES The proposed changes to the James A. FitzPatrick Technical Specifications are addressed below. Minor choages in format, such as type font, margins or hyphenation, are not described in this submittal. These changes are typographical in nature and do not affect the content of the Technical Specifications.
Enggl51 Bases 3.G and 4.6 D Replace the phrase:
"three-channel monitor to provide information on particulate, iodine and anble gas activities in the drywell atmosphere."
with "two-channel monitor to provide information on particulate and noble gas activities in the drywell atmosphere."
Pace 162a. Table 4.6-2 Celete item 3 for iodine analyzer.
11.
PURPOSE OF THE PROPOSED CHANGES The proposed changes remove all references conceming the monitoring of iodine by the drywell Continuous Atmosphere Monitoring (CAM) system.
The drywell CAM system is part of the reactor coolant system leakage detection system incorporating a three-channel combination monitor for counting gross particulate, iodine, and noble gas activities in the drywell atmosphere. The CAM system takes a continuous flow sample and passes it through a shielded assembly containing the detector unit before discharging back into the drywell. Measurements are taken and analyzed to determine if there is abnormal reactor coolant leakage into the drywell.
During the review process in support of replacing the CAM system monitors, the Authority examined the current regulatory regt irements for determining reactor coolant leakage into the drywell. These requirements tReference'1?, finalized by the NRC after the installation of the FitzPatrick CAM system, specify two methods for determining the presence of reactor coolant in the drywel1 and required a third altemative as backup. One method requires the CAM system to monitor for particulates in the drywell atmosphere. The second method requires the monitoring of the sump level and sump flow. The third method, suggested by the NRC staff,is fulfilled by using the CAM system to monitor the gaseous portion of the drywell atmosphere.
Attachment ll to JPN 92 058 SAFETY EVALUATION Page 2 of 4 in accordance with regulatory criteria, there is no nood for monitoring the drywell atmosphere for iodine. Current industry practice (Reference 2) supports this position by requiring CAM systems to monitor particulates and noble gases in conjunction with sump leval/ flow monitoring. Removing the CAM iodine monitoring function from f he Technical Specifications eliminates an unnecessary operational requirement. It plifies equipment maintenance by not requiring testing, calibration, and repairint a
or the iodine portion of the CAM system. Future replacement / upgrading of th6 a system will not require the inclusion of an iodine data channel.
Ill.
SAEETY IMPLICATIONS OF THE PROPOSED CHANGES Regulatory criteria requires three methods for determining the presence of reactor coolant leakage. FitzPatrick's use of a CAM system that monitors both particulate and paseous radioactivity in the drywell atmosphere fulfills two of the three monitoring requirements. Monitoring for airbome iodine radioactivity by the CAM system is not required to meet regulatory criteria which specifies the use of sump flow / level monitoring as the third monitoring methodology. The presence of the iodine monitoring capability provides an unnecessary redundancy for detecting primary system leakage since any coolant leakage with entrained iodine would also include radioactive particulates and gases, lodine airborne concentration monitoring does not increase the capability to detect leakage because the ability of iodine to disperse within the containment atmosphere is essentially identical to that of particulates and noble gases. Considering these points the Technical Specification reqdrement to monitor iodine by the CAM system is excessive and provides no additional safety margin.
The removal of this extra monitoring method will not reduce the plant operator's ability to detect the presence of reactor coolant leakage. Removal of iodine monitoring from the Technical SpecP ':ations will not place FitzPatrick in a position of noncompliance with regulatory criter a. The changes do not aiter the conclusions of the plant's accident analyses as documente j in the FSAR or the NRC staff's SER.
IV.
EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed Amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92c since it would not:
- 1. involve a significant increase in the probability or consequences of an accident -
previously evaluated.
The proposed changes removes the surveillance requirement for monitoring iodine in the drywell atmosphere from the CAM system. These changes do not reduce the CAM system detection ability below regulatory criteria in determining containment atmospheric contamination from coolant leakage. The changes do not affect the ability of the CAM system in performing its intended function. The probability of a coolant leakage is not increased and the ability of plant personnel and equipment to detect and correct such a leakage is not affected. The
, 1 to JPN 92-058 SAFETY EVALUATION Page 3 of 4 j
i proposed dolotion of tho iodino portion of the CAM system will not introduce any additional causes for generating reactor coolant leakago, in addition, thoto is no credit taken in the existing accident analysos for the uso of the CAM system in detecting and proventin0 the occurrenco of a primary coolant boundary failure or for mitigatin0 the offects of the failure. All existing accident analysos resulting in the coloaso of primary coolant into the drywell/supprossion chamber ignoro the look before break scenario and assumos boundary f ailure without CAM detection. Thorof ore, this proposed amendmont does not alter the probability or consequences of any previously ovaluated accident.
- 2. create the possibility of a r.ow or different kind of accident from any accident
~
previously evaluated.
The deletion of an unnecessary instrumentation channel from the technical specification's surveillanco requirements and bases will not creato a now or dif ferent kind of accident. Any coolant laakago with entrained iodino would also include radioactivo particulates and gases. Eit'w.!r of those two laaka00 components would be detected by the remainin0 CAM channels. The chan00s do not affect the ability of any system in performing its intended function. Thero are no equipment, system, or structural modifications associated with those chan0es.
Those changos, thereforo, do not af fect the plant accident analyses as documented in the FSAR or the NRC staff SER.
- 3. involvo a significant reduction in a mar 0 n of safety.
i The removal of an unnecessary instrument channel from the technical specification's surveillanco requirements will not reduce the ability of tho operators to detect and respond to a reactor coolant leaka00. Monitoring iodino by the CAM system was a redundancy established by the Authority prior to finalization of reactor coolant leaka00 detection critoria by the NRC staff.
Removin0 the iodino monitorin0 requiroments will, thereforo, not placo FitzPatrick in a position of noncompliance. Operation of the CAM system without monitoring for iodino will not rolax any controls or limitations and will still provido the samo loval of confidence in ;otecting a reactor coolant leakage.
V.
LM.PLE1 VIE _NTAILQtLQF THE PROPQSED_QHANGES Imptomontation of the proposed chan00s removes a redundant monitorin0 channel originally established for determining reactor coolant leaka00. This removal will not affect the Fire Protection or ALARA Programs at the FitzPatrick plant, nor will the chan00 impact the environment.
.. 1 to JPN 92-058 SAFETY EVALUATION Page 4 of 4 Vh CONCLUSION The chLnges, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59, That is, they:
- 1. will not change the probability nor the consequences of an accident or malfunction of equipment important to safety as previously evaluateriin the Safety Malysis Report:
- 2. will not increase the possibility of an accident or malfunction of a type different from any previously evaluated in the Safety Analysis Report:
- 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 defined in 10 CFR 50.92.
Vll. REFERENCES
- 1. NRC Regulatory Gu!de 1.45, " Reactor Coolant Pressure Boundary Leakage Detection Systems", dated May 1973.
- 2. NRC NUREG-0123, " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/5)," Revision 3, dated Fall 1980,
- 3. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, Section 4.10.3.4, " Leakage Detection System," through Revision 5, dated January 1992.
- 4. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated November 20,1972.
- 5. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report Supplement No.1, dated February 1,1973.
l
- 6. James A. FitzPatrick Nuclear Power Plant Safety Evaluation Report Supplement No. 2, dated October 4,1974.
ATTACHMENT 111 to JPN-92-058 PROPOSED TECHNICAL SPECIFICATION CHANGES PRIMARY CONTAINMENT IODINE MONITORING SPECIFICATIONS MARKUP OF TECHNICAL SPECIFICAT1QN PAGES (JPTS-91-006)
New York Power Authority l-JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR 59
).6 4.fi 111513 (cout'd)
JAntrr laakage were also considered in than the uponitudo speciflod can be r
crahlishing the l imil t s.
The detectnd reasonthly is. n vaatter of a h>h.svlor of cract.s in piping systems few hours utillrine, the available h.a s been experimentally and leakago detectlon s t.hemes, and if analyt icall y investigated a:s part of t he origin cannot. he det er nalned in a t li r ilSM C-r.gainw s'el ste.netor l'r inna ry a ca son.s hi y short t line, the I'l a n t Cs.'.n l a n t. Sys t e se linpt oir e study (the t.h oi I d 1 0 chut doun t o aller.r fis rt her 1Is.e 1.upture Study), t;os t; utili zirig I nvest igat lo:n and con n ecti ve act ion.
t h':
sta t.
obtained les this nLudy judicaten t '... : leakage f r o:n a cract:
Tlic capacity of tho drywell sump enn bu - d *: t t..:t ed lef tere
( l' crack pua ps in 100 gp:n, and the capaci t y gious to das qci ous or t,ritical of t he dryaell c<pilpement. dralr> tank
.i ro ley ea'ic hin i c.i l l y or t he r sra l l y puieg ns is also 100 gia, l'c:aoveel,of i nence.1 cycIle l o.nl i ng, or otrc:2a
?,o 9pu f rone either of ti.cso susp's sus:osion c ra s:k i s:et or soae other cen, ho a ccm pi l nhed with co rs -
r :shni a.:n cha t.ict er i z ed by gradual r.iderable margin.
a s.u L growth.
'Ihis evidence f.c.ppe:.t s that_
for leakage coencultat TI.u perforreance of the 11cac t o r 9: :ater than the l i r.i t speelfled for coolant 1.eakane Detection Systea l
unidenti!!cd l e a t: aue,
t_he pan-ullt he (valuctOd during 110 first 5 1.a b i l i t y i s suaall t ha t_ Imperfections yr of plant operation, and the oT crach:s
" a rs soc i a t ed uitti siecle conclusloas of t his evaltia tion ul l t Iqatage
. uoulil grow rapidly.
i.e reg os ",e d to the 1118C.
I!oue v.: r,
the es t abl I shra, cut of a l l oustel o unidesat i f ied leakago I t.
In estimated tisat the ruain steam quenter than t h.s t. ::1ven in 3. f.. t) line t ainnel leakage ele t ec t o rs' are en t he: basis of the data prescent l y ca p.ihl e of detecting a Icak on t lic
.sva ll able veuld 1: s pr.?:satur o l;ccause r.seler of 3,500 lb/hr.
The syst em of uncettaintten acnociated with tieo p*:rl.on mance ull t be evaluated dierlm; n
d.: t a. For Ica!. age of t he order of 5 the f i r r.t.
5 yr of plant operation, e;p.i a s t.pecified in 3.6.D, the amt t h.:
conclusions of the cr.g:cs inesota l and coalytical dat a craluction will be acported to the ersognut a reasoaahic smargin of littC.
/'
safety su :!i t h. t Icavage ot'this f
1ho scactor coo' int leaikage eletection systems sesyr.i ttede would snot r arstel t f r o,e a
crack a:.r.t rea ch i ng t he c r i t l ea l size consist of the '~ywall an=P smanitoring systese i ar rapid piepagat. inn.
leakage less and the drywell continuous atmosphere sinetitoring r.y :s t em.
't he..rywel l cont i nianus n a mnspl.er e j
enal torin I systesi ut t il res ajthree-chaeusel monito to provido in for ma t l ose oss giar t i cul a t e, le= lina arul esolite nas act ivitics In t he drywell atmont.bere, bf Irutepenale:nt atel s cehiswlant systems as o pr o-
- as vided to per foren t hin feenct iori.
Thi s tsyst ein
,4 siq=plomonte tien ela ywe l l cus>p rwini t or ing systese ln5V b
'" ^"'"**'"' *""" ~^' ' ' " ' " ' ' " ' " ^ ' " " " " " ' ' " '
fro.= the reactor coolant : syn t ese.
In the event that s hn dr ywell rewit Isinensas atetssplier e sa.niif or ing i 151 Amen.l nent lla.
3
, y,,,,,,,,,ogo,,,,,,,, y na,,,,,p i,,,,, g i,,,,,, u,,
on a :-rlmile. basis t o monitnr.tryu.;t l act ivi ty.
{
i JAFNPP 1
~
Table 4.6-2 Minimum Test and Calibration Frequency for Drpell Continuous Atrnosphere Radioactivity Flon-i tor incy_Sys tem Sennor Inst. Channel Inst. Functional Test Calibration Che.k l.
Air Particle Analyzer None once/3 mos.
ence/ day Once/3 mos, once/elay 2.
Gascous. Activity Analyzer tione~
Once/3 rnos.
ence/.la y Isone
[J.
Iodine Analyzer t
k ii i
I i
i a
162a f
Amendment No.
3 r
INSERT "A"
%c-channel monitor to provido infor tnation on particulato and nobio gas activillos in the drywoll atmosphere P
6 i '
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