ML20132F523

Requests Addl Info Re Request for Exemption from Requirements 10CFR50,app R as Applied to Ja FitzPatrick Nuclear Power Plant So low-pressure Injection Sys May Be Used to Achieve Safe Shutdown in Six Fire Areas

ML20132F523
Person / Time
Site:	FitzPatrick
Issue date:	12/18/1996
From:	Cotton K NRC (Affiliation Not Assigned)
To:	William Cahill POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
NUDOCS 9612240320
Download: ML20132F523 (7)

Text

. . December 18, 1996 Mr. William J. Cahill, Jr.

Chief Nuclear Officer Power Authority of the State of New York 123 Main Street White Plains, NY 10601

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR EXEMPTION FROM SECTION III.G.'1,-III.L.1, AND III.L.2 of APPENDIX R TO 10 CFR PART 50 (TAC NO. M94518) .

Dear Mr. Cahill:

g ,

The enclosed re' quest. for. additional information (RAI) relates to your i

~

request for exemption dated' January 12,1596,..?fromtherequirementsof10CFR Part 50, Appendix R as they ' apply to the James'A. FitzPatrick Nuclear Power Plantsothatlow-pressureinjhc'tionsystemsmay'beusedtoachievesafe 1

~ i shutdown in"sixlfire areas. ,

E Sincerely, v .

'fgj Karen R. Cotton, Acting Project Manager Project Directorate I-l Division of Reactor Projects - I/II i Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Request for Additional Information NBC HLE CENTER COPY cc w/ encl: See next page l 1

DISTRIBUTION:

Docket File SVarga Slittle ACRS -

PUBLIC JZwolinski KCotton CCowgill,RGN-I PDI-1 Reading SBajwa 0GC DOCUMENT NAME:G:\FITZ\FIM94518.RAI \

To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" - Copy.with attachment / enclosure "N" - No copy 0FFICE PM:PDI 1 lE LA:PDI 1 3 i l D:PDI-1rfl[/ /A/l l l NAME KCotton:nw SLitttef# S8e j waM 8 ' f DATE 12//g/% 12/lR/% 12/ // /96 12/ /96 12/ /96 ,

Official Record Copy 240060 9612240320 961218 PDR ADOCK 05000333 p PDR

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UNITED STATE 3 NUCLEAR REGULATORY COMMISSION l f WASHINGTON, D.C. 2005Hooi l

%g***** / December 18, 1996 1

Mr. William J. Cahill, Jr.  !

Chief Nuclear Officer 3

Power Authority of the State of New York i

. 123 Main Street l White Plains, NY 10601 j

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR EXEMPTION 1 FROM SECTION III.G.1, III.L.1, AND III.L.2 of APPENDIX R T0 10 CFR l

PART 50 (TAC NO. M94518) 1

Dear Mr. Cahill:

l The enclosed request for additional information (RAI) relates to your l request for exemption dated January 12, 1996, from the requirements of 10 CFR Part 50, Appendix R as they apply to the James A. FitzPatrick Nuclear Power Plant so that low-pressure injection systems may be used to achieve safe )

shutdown in six fire areas.

Sincerely, l

V1Lb0+fM

, Karen R. Cotton, Acting Project Manager Project Directorate I-1 Division of Reactor Projects - I/II

Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Request for Additional Information 4 cc w/ enc 1: See next page i

I

William J. Cahill, Jr. James A. FitzPatrick Nuclear '

Power Authority of the State Power Plant of New York  ;

cc:

Mr. Gerald C. Goldstein Regional Administrator, Region I Assistant General Counsel U.S. Nuclear Regulatory Commission l Power Authority of the State 475 Allendale Road i of New York King of Prussia, PA 19406 1633 Broadway New York, NY 10019 Mr. F. William Valentino, President i New York State Energy, Research, Resident Inspector's Office and Development Authority U. S. Nuclear Regulatory Commission Corporate Plaza West P.O. Box 136 286 Washington Avenue Extension Lycoming, NY 13093 Albany, NY .12223-1253 Mr. Harry P. Salmon, Jr. Mr. Richard L. Patch, Director Resident Manager Quality Assurance James A. FitzPatrick Nuclear Power Authority of the State Power Plant of New York l P.O. Box 41 123 Main Street l Lycoming, NY 13093 White Plains, NY 10601 j Ms. Charlene D. Faison Mr. Gerard Goering <

Director Nuclear Licensing 28112 Bayview Drive l Power Authority of the State Red Wing, MN 55066 l of New York 123 Main Street Mr. James Gagliardo White Plains, NY 10601 Safety Review Committee 708 Castlewood Avenue Supervisor Arlington, TX 76012 Town of Scriba Route 8, Box 382 Mr. Arthur Zaremba, Licensing Oswego, NY 13126 Manager James A. FitzPatrick Nuclear Mr. Robert G. Schoenberger, Power Plant Vice President P.O. Box 41 and Chief Operating Officer Lycoming, NY 13093 Power Authority of the State of New York Mr. Paul Eddy 123 Main Street New York State Dept. of White Plains, NY 10601 Public Service 3 Empire State Plaza, 10th Floor Charles Donaldson, Esquire Albany, NY 12223 Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271

REQUEST FOR ADDITION INFORMATION  !

REQLEST FOR EXEMPTION FROM SECTION III.G.1, ,

III.L.1, AND III.L.2 0F  ;

APPENDIX R TO 10 CFR PART 50 l JAMES A. FITZPATRICK NUCLEAR POWER PLANT

1.0 BACKGROUND

By letter dated September 5, 1996, the NRC Office of Nuclear Reactor

, Regulation (NRR) forwarded the results of its evaluction of the post-fire shutdown reassessment of the James A. FitzPatrick Nuclear Power Plant to the licensee, Power Authority of the State of New York (PACNY). As a result of its review, the staff determined that the licensee's proposed use of low pressure injection systems (LPIS):

(a) would not allow hot-shutdown conditions to be maintained, as l required by Section III.G.1 of Appendix R to 20 CFR Part 50- 1 (b) would not allow process system variables to rer.sain within those

predicted for a loss of the normal a.c. power source, as required by  !

Section III.L.1 of Appendix R to 10 CFR Part 50; and I i

(c) would not allow the reactor coolant level to be maintained above the top of the core, as required by Section III.L.2.b of Appendix R to '

10 CFR Part 50.  ;

Based on these findings, the staff concluded that PASNY's pror.osed use of low

. pressure injection systems as a means of achieving safe shutdown conditions in the event of fire in areas of the plant not requiring an alternative shutdown capability, would not satisfy the requirements of Section III.G and Section III.L of Appendix R to 10 CFR Part 50, and, therefore, recommended that PASNY either:

. (a) ensure the availability of a high-pressure injection system (i.e.,

reactor core isolation coolant (RCIC) or high pressure-coolant injection (HPCI) in the event of fire in these areas, or (b) seek an exemption from the specific requirements of the regulation not satisfied by the proposed approach.

By letter dated January 12, 1996, PASNY submitted a request for exemption from 10 CFR Part 50, Appendix R to allow the use of low-pressure injection systems as a means of achieving post-fire safe shutdown conditions in the event of fire in a total of six fire areas of the James A. FitzPatrick Nuclear Power

Plant

Fire Areas, IX, X, XI, XV, XVII, and XVIII.

Specifically, to allow the use of LPIS as a means of accomplishing the reactor

coolant make-up shutdown function, PASNY seeks an exemption from the following specific sections of Appendix R to 10 CFR Part 50

(a)Section III.G.1, to the extent that the proposed approach will not be capable of achieving and maintaining hot shutdown conditions; Enclosure

_ . _ _ . _ _ _ . . _ _ _ __.._________.__m_ _ . _ . - _ _ _ .

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i (b)Section III.L.1, to the extent that the proposed approach is not  !

i capable of maintaining reactor coolant process variables within i j those predicted for a loss of normal a.c. power; and i i *

(c)Section III.L.2, because the proposed approach is not capable of l j- maintaining the reactor coolant level above the top of the core. l l I

At the request of NRR, Brookhaven National Laboratory (BNL) reviewed the '

! subject exemption request. Based on our review of this document, we have prepared the following questions, concerns and comments:

! 2.0 REQUESTED INFORMATION i l

l The post-fire safe shutdown criteria of Sectior:s III.G.1 and III.G.2 are i i directed at ensuring that at least one train of redundant systems, canable of achievina and maintainina hot shutdown conditions, remains operable in the l event of fire in any plant area. Where the protection of systems capable of

[' satisfying the hot shutdown performance criteria of Sections III.G.1 and III.G.2 is not assured,Section III..G.3 requires an alternative or dedicated shutdown capability which is independent (physically and electrically) of the fire area, room, or zr.nc under consideration.

With regard to determining whether a chutdown capability is " redundant" (per lil.G.1 and III.G.2) or " alternative" (per itI.G.3 and III.L), Generic Letter 86-10 provides the following staff positier..

(a) Response to Question 3.8.3:

...If the systen is being used in lieu of the preferred systen because the redundant components of the nreferred systen do not meet the separation criteria of Section Ill.G 2, the systen is considered an alternative shutdown capability." (emphasis added)

(b) Response to Question 5.1.2 "For the purpose of analysis to Section III.G.2 criteria, the safe shutdown capability is defined as one of the two normal safe shutdown trains.." (emphasis added).

(c) Response to Ques'. ion 5.2.3 "The only requirenent for nost-fire operating procedures is for those areas where alternative so,. :own is required. For other areas of the  !

plant, shutdown would be achtsved utilizing one of the two normal trains of shutdown systens." (emphasis added).

1 The use of LPIS is not the preferred means of accomplishing the reactor core l coolant make-up function in a boiling-water reactor. The normal, preferred, method of shutdown in the event of fire is through the use of e.g., HPCI or ,

RCIC. In its July 22, 1994 response to a staff request for additional information (RAI) dated May 18, 1994, the licensee concurs with this position, and states that the proposed approach (i.e., LPIS) will only be used when all other means of shutting down the reactor are not available, or when the use of high pressure systems must be avoided. This understanding is reiterated by PASNY in its January 12, 1996 exemption request which states: "Nigh Pressure Injection Systens would normally be used to achieve and nafntain hot shutdown in the event of fire in Fire Areas IX, X, XI, XV, XVII, and XVIII." In the event that fire prevented the use of the preferred shutdown method (i.e., HPCI or RCIC), PASNY states that Shutdown Method 3, which relies on the use of LPIS (ADS /LPCI or ADS /CS) controlled from the main control room, would be availarle, and capable of achieving cold shutdown conditions.

The suff has approved the use of LPIS as a means of providing an alternative shutdown capability (

Reference:

NRC Memorandum, L. S. Rubenstein to R. J.

Mattson, dated December 3, 1982, "Use of the Automatic Depressurization (ADS) and Low Pressure Coolant Injection (LPCI) to Meet Appendix R, Alternate

' Shutdown Goals)." The basis for this acceptance rests, in part, with the defense-in-depth principles for fire protection. Specifically, when alternative shutdown capabilities are provided to satisfy Section III.G.3 of Appendix R, the regulation imposes an additional requirement of fire detection and fixed fire supprusion systems in all areas where the alternative shutdown capability is credPad for accomplishing required shutdown functions. These additional fire safety features serve to limit the probability of fire growth and damage, thereby minimizing reliance on the "less-than-preferred" alternative capability to accomplish required shutdown conditions. Under the regulations, areas of the plant which do not require an alternate shutdown capability may not be provided with an equivalent level of fire protection.

Based on the above, the proposed use of LPIS to perform the reactor coolant make-up function does not ppear to satisfy the hot shutdown performance criterion of Section III.G. Additionally, it appears the proposed approach LPIS is being used in lieu of preferred systems HPCI or RCIC because redundant components of the preferred system do not meet the separation criteria of Section III.G.2. Therefore, please address the following:

1. The proposed LPIS approach does not appear to satisfy the " hot shutdown" performance criterion of Section III.G.1, III.G.2, and III.G.3 of Appendix R to 10 CFR Part 50. Generic Letter 86-10 provides further clarification and staff positions with regard to defining " alternative" and " redundant" shutdown capabilities. In light of these requirements, it appears the proposed approach is providing an alternative shutdown capability for the identified fire areas. Please explain why the use of LPIS is not identified by 1 PASNY as providing an alternative shutdown capability for Fire Areas l IX, X, XI, XV, XVII, and XVIII. j l

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2. Fire Areas IX, X, XI, XV, XVII, and XVIII are described in the PASNY

revised analysis (" Safe Shutdown Capability Reassessment 10 CFR Part 50 Appendix R, James A. FitzPatrick Nuclear Power Plant," dated November 1992) as satisfying the separation and protection requirements of Section III.G of Appendix R. However, as described 4

above, LPIS appears to be providing an alternative shutdown

! capability for these areas. Therefore, please explain why Fire Areas IX, X, XI, XV, XVII, and XVIII have not been designated as alternative shutdown fire areas.

t 3 3.Section III.G.3 of Appendix R states that for alternative shutdown i

' capabilities, " fire detection and a fixed fire suppression system shall be installed in the area, room or zone under consideration."

, For Fire Areas IX, X, XI, XV, XVII and XVIII provide information i which demonstrates that this requirement of Append'x R is met. or i

provide justification why this requirement is not met and an exemption for this requirement should be granted (i.e. equivalent safety exists).

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