ML20141M941
| ML20141M941 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/25/1986 |
| From: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 JPN-86-06, JPN-86-6, NUDOCS 8603030089 | |
| Download: ML20141M941 (7) | |
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o 123 Main Street Whte Pfanns, New brk 10601 l
914 681.6240
- > NewYorkPower f"2"" s W Authority redruary 25, 1986 RYF86-06 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.
C.
20555 Attention:
Mr. Daniel R. Muller, Director BWR Project Directorate No. 2 Division of BWR Licensing
Subject:
James A.
FitzPatrick Nuclear Power Plant Docket No. 50-333 Regulatory Guide 1.97 Revision 2 Implementation Report - Correction Regarding Drywell Sump Level Instrumentation
References:
- 1. NYPA letter, J.
C.
Brons to D.
B. Vassallo, dated November 30, 1984 (JPN-84-77),
transmitted a report describing Authority plans to implement Regulatory Guide 1.97 Revision 2 at the FitzPatrick plant.
Dear Sir:
The Authority's November 30, 1984 report (Attachment 1 to Reference 1) described how the guidance of Regulatory Guide 1.97 Revision 2 will be implemented at the FitzPatrick plant.
The Authority identified an error in that report during design work being performed for installation of Regulatory Guide 1.97 modifications. Specifically, the first paragraph, third sentence of Section 3.4 ("Drywell Sump Level" on page
- 8) incorrectly states that one of the narrow range drywell equipment and drain cumpn "...has a seismically and environmentally qualified level transmitter." Neither of the two currently installed level transmitters are environmentally qualified, nor does 10 CFR 50.49 required that they be environmentally qualified.
The Authority has determined that it is not necessary to upgrade the existing drywell sump level instrumentation. justifies this determination.
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Should you.or your staff have any questions concerning this matter, please contact Mr. J. A. Gray, Jr. of my staff.
Very truly yours, 1
on Brons
.ienior Vice President lluclear Generation
/
cc: Office of the Resident Inspector U. S.
Nuclear Regulatory Commission P. O.
Box 136 Lycoming, New York 13093 t
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A ATTACHMENT 1 TO JPN-86-06 New York Power Authority James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 DPR-59 Regulatory Guide 1.97 Revision 2 Implementation Report - Correction of Information Regarding Drywell Sump Level Instrumentation 4
As a result of design work performed for installation of modifications associated with Regulatory Guide 1.97, the Authority has identified an error in the report (Attachment 1 to Reference 1) sent to the NRC 3
describing these modifications. Specifically, the first paragraph, third sentence of Section 3.4 ("Drywell Sump Level" on page 8) incorrectly states that one of the i
narrow range drywell equipment and drain sump transmitters "...has a seismically and environmentally qualified transmitter." Currently, neither of the two installed level transmitters are environmentally qualified, nor are they required to be by 10 CFR 50.49 (Reference 7).
The NRC recently issued a preliminary Technical Evaluation Report (Reference 2) on the FitzPatrick Regulatory Guide 1.97 implementation report. Based on the information provided in the Authority's report, the NRC found the Drywell Sump Level instrumentation acceptable.
The error identified by this letter also appears in the NRC's preliminary Technical Evaluation Report.
Despite the fact that the sump level transmitters i
are not environmentally qualified, the Authority considers the installed instrumentation acceptable for the following reasons.
- 1. The Drywell Leakage Detection system consists of 4
two sub-systems: the Drywell Equipment Drain Sump l
Leakage Detection system and the Drywell Floor Drain Sump Leakage Detection system. The Drywell Floor Drain Sump Leakage Detection system is associated with unidentified sources of leakage 4
from equipment in the drywell. The Drywell Equipment Drain Sump Leakage Detection system collects leakage from places in the Reactor Coolant System where leakage is expected: pump packing glands, valve stems and other seals.
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Details of this system are described-in Section 4.10
(" Reactor Coolant System Leakage Detection and Leakage Rate Limits") of the updated FitzPatrick Final Safety Analysis Report (Reference 4).
The Drywell Leakage Detection system was not i
designed to fulfill the requirements of Regulatory Guide 1.97 Revision 2 for type B or C drywell sump level instrumentation. The system was designed "...to detect abnormal leakage before the results become unacceptable" (page 4.10-1, Reference 4)..This system's design basis is to identify small leaks as an accident precursor.
l The system has two sumps: one for each of the two sub-systems. Both sumps are isolated by a primary containment isolation signal to prevent their contents from being pumped out of the drywell (primary containment) in the event of an accident. This isolation effectively eliminates these sumps as a source of information following an accident.
4 The FitzPatrick Technical Specifications (Section
- 3. 6. D) require that these systems be operable during reactor power operation.
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- 2. The existing wide-range, drywell level instrumentation will provide a meaningful indication of water inside the drywell in the i
event of an accident.
Two wide-range drywell level channels, currently installed at FitzPatrick, meet Quality Assurance Category I design criteria.~The transmitters (23 LT-203A1, 23 LT-203A2, 23 LT-203B1 and 23 LT-203B2) are environmentally and seismically qualified, and seismically mounted. These instruments directly indicate water level in the drywell and will provide meaningful information following an accident. Drywell level is displayed in the FitzPatrick Control Room with a range of twenty-two to one hundred and six (22 - 106) feet. (These instruments are futher described in Section 3.4 of Reference 1.)
- 3. The Drywell Leakage Detection system was designed i
to detect small increases in leakage from drywell equipment rather than to determine the level of water inside the drywell following an accident.
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The accidents for which these transmitters would have to be environmentally qualified would render the Drywell Leakage Detection System useless.
Following an accident, the drywell sumps will flood very quickly. Once the sumps have been filled to capacity, the sump level instrumentation will cease to provide leakage rate or containment water level information.
Therefore, the qualification of these level transmitters to withstand the environmental conditions postulated to follow a design basis accident would not increase the amount of information avaliable to an operator and therefore would not be of any benefit.
- 4. The Drywell Leakage Detection sump level instrumentation does not initiate the operation of any emergency core cooling equipment, nor does it alert the operator to do so manually.
5.
Section 6,
" Regulatory Guide 1.97 - Application to Emergency Response Facilities" of Supplement 1 to NUREG-0737 (Reference 6) describes the fundamental requirements for implementing Regulatory Guide 1.97. Section 6.1.b of Supplement 1 specifically states:
"It is acceptable to rely on currently 4
installed equipment if it will measure over the range indiciated in Regulatory Guide 1.97 (Rev. 2), even if the equipment is l
presently not environmentally qualified.
i Eventually, all the equipment required to monitor the course of an accident would be environmentally qualified in accordance with the pending Commission rule on environment qualification."
These Drywell Leakage Detection transmitters are i
currently installed equipment. Based on the intended function of the Drywell Leakage Detection System, as described in item 1 above, the environmental qualification rule (Reference
- 7) does not require that this equipment be i
qualified.
Section 2 of Supplement 1 to NUREG-0737, "Use of Existing Documentation" futher states that:
"... Regulatory Guides are to be considered 3
l as guidance or as an acceptable approach to meeting formal requirements. The items by virtue of their inclusion in these documents shall not be misconstrued as requirements to be levied on licensees or as inflexible criteria to be use by NRC staff reviewers."
Regulatory Guide 1.97 Revision 2 is among the documents included in Supplement 1 to NUREG-0737.
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References:
- 1. NYPA letter, J.
C.
Brons to D.
B. Vassallo, dated November 30, 1984 (JPN-84-77), transmitted a report describing Authority plans to implement Regulatory Guide 1.97 Revision 2 at the FitzPatrick Plant.
- 2. NRC letter, D.
B. Vassallo to J.
C.
Brons, dated November 5,
1985 transmitted a preliminary Technical Evaluation Report regarding the implementation of Regulatory Guide 4
1.97 Revision 2 at FitzPatrick.
- 3. NYPA letter, J.
C.
Brons to D.
P. Muller, dated December 24, 1985 (JPN-85-91) commented on preliminary Technical Evaluation Report "Conformance to Regulatory Guide 1.97, James A.
FitzPatrick Nuclear Power Plant" published October 1985.
- 4. James A.
FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report, dated July 1985.
- 5. PASNY letter, J.
P.
Bayne to T. A.
Ippolitto, dated April 1, 1981 (JPN-81-25) regarding NUREG-0578, Item 2.1.4, describes modification to containment isolation signals associated with drywell equipment drain sump discharge valve (20-AOV-95) and drywell floor drain sump valve
]
(20-AOV-83).
- 6. NRC Generic Letter 82-33, dated December 17, 1982.
Includes Supplement 1 to NUREG-0737.
7.
10 CFR 50.49 " Environmental qualification of electric equipment important to safety for nuclear power plants."
48 FR 2729 published February 22, 1983.
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