ML20149L462
| ML20149L462 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 02/17/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20149L461 | List: |
| References | |
| NUDOCS 8802240243 | |
| Download: ML20149L462 (4) | |
Text
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[ge no s.,g UNITED STATES 6
y e< 1g NUCLEAR REGULATORY COMMISSION
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0 4,.o.4 SAFETY EVALUATION BY THE OFFICE OF N!! CLEAR REACTOR REGULATION R1L,ATEDTOAMENDMENTNO. 114 TO FACILITY OPERATING LICENSE NO DPR-59 POWER AUTHORITY OF THE STATE OF NEW YORK JAME$ A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 INTR 000CT.*0N NUREG-0737, item III.D.3.4, approved for implementation by the Commission, recuires that licenseec assure that control room operators will be adequately protected against the effect of an accidental release of toxic and radioactive 9dbas. % that the nuclear power plant can be safely operated or shut down under
'cesig1 bas?s accident conditions, as delineated in GDC-19 of Appendix A to
Item III.D.3.4 also states that changes to technical specifications i
vill be rwrired. Generic Letter 83-36 provided staff guidance on technical specif' cation (TS) changes for RWRs for NUREG-0737 items, including Item III.D.3.4.
The generu. letter stated that for those items where the licensee identifies devdions between the existing plant TS and the BWR Standard Technical Specifi-cations which were provided as guidance, or in the case of absence of a specific technical specification, licensees wre to submit an application for a license amendment with the appropriate TS changes.
In res;nnse to the ibove requirements identified in item III.D.3.4, the licensee submitted an evaluation of the FitzPatrick control room habitability tystem by lettfr ' dated August 13, 1981.
As a result of this evaluation, the lic%e r,roposed' four measures to be implemented to meet the requirements spe::ified in Item III.D.3.4.
The staff accepted the licensee's evaluation and
,woooked trenures as discussed in its safety evaluation transmitted to the
'Ifeensee ny letter dated February 24, 1982.
In the safety evaluation, the sta#f requested that the licensee propose TS upon completion of the chances identifieo. Thrw of the four measures have been completed.
The remaining measure conctens periodic makeup air flow verification testino for the control re m emergency filtration system By letter dated April 15, 1986, in accordance s
with a connitaent made in their letter dated August 13, 1981, the licensee submitted a proposed charge to the FitzPatrick TS to incorporate a periodic makeup air flow verification test requirement.
As discussed below, the staff has found the proposed TS change to be acceptable.
However, in the course of reviewing the proposed TS change (which is subject of this amendnent), the staff noted that the licensee has not proposed complete and adequate U changes for the control room habitability system (Item III.D.3.4),
as delineated in Generic letter 83-36. This conclusion is based on a review of the licensee's letter dated December 6, 1984 (containing'the litersee's response to GL 83-36), as well as a review of the licensee current TS. A meeting was held with the licen:ee on July 31, 1986 to discuss this matter, e802240243 e90217 PDR ADOCK 03000333 p
By letter dated December 19, 1986, in response to the concerns expressed by the staff, the licensee provided a detailed comparison of the current FitzPatrick TS to the BWR Standard Technical Specifications (STS) which were provided as guidance in GL 83-36. The licensee concluded that the differences between the FitzPatrick TS and the STS do not result in a lower level of safety concerning control room habitability.
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EVALUATION In the course of reviewing the additional needed TS changes, the staff determined the following:
the FitzPatrick control room emergency filtration system (CREFS) consists of two 100 percent capacity units, each consisting of a prefilter, HEPA filter, two charcoal absorbers in series, and a second HEPA filter.
Each filter unit provides up to 1,000 cfm of outside makeup air in emergency condition to maintain a positive pressure in the control room.
The current FitzPatrick TS permit reactor operation for up to 30 days with one emergency filter unit out of service while the STS specify a seven day limiting condition for operation (LCO).
The FitzPatrick TS also permits reactor operation i
for up to seven days with both filter units inoperable while the STS requires the reactor to be in hot shutdown within six hours and cold shutdown within the i
following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
The licensee stated in their comparison that the current FitzPatrick TS are both apprnpriate and justifiable for the following reasons:
1)
Lack of staff criteria for detennining allowable out-of-service times (A0Ts).
The licensee cited as an example of the lack of guidance on A0Ts, the fact that the high pressure coolant injection (HPCI) system, which they con-sidered significantly more important to reactor safety than the CREFS, has a TS LCO of 7 days.
The staff notes that three means of reactor core cooling (the HPCI system, reactor core isoittion cooling system, and automatic depressurization/ low pressure core injection system) are ensured t
to be available by TS while no other alternate system is available as a backup to the CREFS to protect the control room operators from radiation following a design basis accident.
Further, the HPCI system is required to be operable only during reactor operation, modes 1, 2, and 3 while the CREFS is required to be operable in all modes of reactor operation including refueling.
Control room habitability is fundamental to the safe operation of nuclear power plants. The staff has determined that requirements of the STS are appropriate and the licensee has not provided sufficient justification for not adopting STS. The staff concludes that the licensee's comparison is incorrect and inappropriate.
2)
Relative importance of the CREFS.
The licensee stated in part, "Recent research on the contribution of containment leakage to risk illustrates the lower relative importance of the Control Room Emergency Filtration System.
NUREG/CR-4330 concludes that containment failure,
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3-when compared to containment leakage, is the dominant contributor to risk. This report further concludes that the current limits on contain-ment leakage could be relaxed without an unacceptable increase in risk."
The licensee's position does not provide a direct reference to specific research on the contribution of containment leakage to risk. NUREG/CR-4330 only describes the results of surveys conducted to identify regulatory requirements that could potentially be relaxed or eliminated without compromising public health and safety.
The study is based on a ifmited sanpling and is neither precise nor rigorous.
The criteria for control room habitability system design are still applicable, and the staff finds the licensee's argument insufficient to justify deviation from the STS.
3)
New accident source terms.
The licensee stated in part, "Design basis calculations used to determine post-accident doses to control room inhabitants are based on very conservative assumptions.
Source terms used in these calculations are significantly higher than the actual release fractions. When current research on accident source terms is considered in these calculations, the importance of the emergency ventilation system will be further reduced because the consequences of an inoperable emergency ventilation system will be i
significantly reduced."
Accident source terms used to determine post-accident doses to the FitzPatrick control room operators are based on existing criteria which include 10 CFR 100 (TID 14844) and Regulatory Guide 1.3.
The currer' research efforts on accident source terms are not completed and, u-appropriate changes to the criteria are approved, new source tems not be considered in licensing actions at this time.
The staff, therefore, finds the licensee's argument to be invalid.
Based on the above evaluation, the staff concludes that the licensee has not provided sufficient justification to support the current FitzPatrick TS concerning operability of the control room emergency filtration system, in accordance with the requirement of NUREG-0737. Item III.D.3.4.
Specifically, the licensee's TS LCO permits the system to be out of service for periods of time in excess of that considered appropriate for ensuring habitability of the control room, as required by GDC-19 and as endorsed in the technical specification guidelines contained in GL 83-36.
It is therefore the staff's position that the licensee propose revised TS LCO's in accordance with the GL 83-36 guidelines, or provide adequate justification i
for an alternative LCO.
The staff has also reviewed the licensee's discussion of other deviations from the control room habitability STS, as provided in the December 19, 1986 letter.
We find these deviations to be minor in nature and, therefore, acceptable as they will not impact assurance of the operability of the system.
4 0
4 With regard to the proposed TS change which is the subject of this amendment, the staff also finds the preposed TS change to incorporate periodic makeup air flow verification testing for the CREFS to be acceptable as it will ensure that adequate makeup air is provided under emergency conditions to maintain pressuri-zation of the contrcl room envelope.
ENVIRONMENTAL CONSIDERATION This amendment involves a change in the installation or use of a facility 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 he released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Comission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public coment on such finding. 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.
CONCLUSION Based on the evaluation provided above, this amendment approves the proposed TS charse incorporating periodic makeup air flew verification testing for the CREFS into the FitzPatrick TS.
We have concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations and the issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public.
Dated: February 17, 1988 PRINCIPAL CONTRIBUTOR.
i J. Lee