ML20198B517

Safety Evaluation Supporting Amend 248 to License DPR-59

ML20198B517
Person / Time
Site:	FitzPatrick
Issue date:	12/11/1998
From:	NRC (Affiliation Not Assigned)
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ML20198B514	List: ML20198B509 ML20198B517
References
NUDOCS 9812210003
Download: ML20198B517 (4)

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UNITED STATES l

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NUCLEAR REGULATORY COMMISSION t

WASHINGTON, D.C. 20066 4001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. N TO FACILITY OPERATING LICENSE NO. DPR-59 POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR FOWER PLANT DOCKET NO. 50-333

1.0 INTRODUCTION

On March 30,1998, the Power Authority of the State of New York (the licensee, also known as j

the New York Power Authority) requested changes to the technical specifications (TS) for the James A. FitzPatrick Nuclear Power Plant. The proposed TS consist of a revised definition for i

logic system functional tests (LSFT) and changes in LSFT fre'quency for certain instrumentation. The licensee provided supplementalinformation on October 27,1998, documenting completion of a commitment to recalibrate an instrument. The supplemental information does not affect the NRC staff's proposed finding of no significant hazards consideration.

2.0 BACKGROUND

Improved reactor fuels allow licensees to consider an increase in the duration of the fuel cycle for their facilities. The NRC staff has reviewed requests for individual plants to modify TS surveillance Intervals to be compatible with a 24-month fuel cycle. Generic Letter (GL) 9104,

" Changes in Technical Specification Surveillance Intervals to Accommodate a 24 Month Fuel i

Cycle," was issued on April 2,1991, providing generic guidance to the licensees for preparing i

such license amendment requests. By following the GL 91-04 guidance, surveillance interval TS would be revised to require performance of instrument surveillance testing on a refueling interval. Additionally, the TS provision to extend surveillances by 25 percent of the specified i

interval would extend the time limit for completing these surveillance from the proposed 24 months to a maximum of 30 months. GL 91-04 also includes requirements to evaluate he effect on safety for an increase in surveillance intervals to accommodate a 24-month fuel cycle.

This evaluation should support a conclusion that the effect on safety is small, and the historical maintenance and surveillance data do not invalidate this conclusion. GL 91-04 also required addressing the issue of instrument uncertainties, instrument drift, equipment qualification, and vendor maintenance requirements in order to ensure th'at an extended surveillance interval does not result in exceeding safety analysis assumptionc. GL 91-04 also specified that the licensee incorporate a plant-specific program to monitor and assess the long-term effects of instrument drift and provide continuing data to evaluate the surveillance extension. s i

Additionally, to address the problems of testing safety related logic circuits, the staff issued i

GL 96-01," Testing of Safety-Related Logic Circuits," on January 10,1996. GL 91-06 required licensees to compare certain safety-related system instnament logic against plant surveillance 1

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l test procedures to ensure that all portions of the logic circuitry are adequately covered in the

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surveillance procedures to fulfill the TS requirements.

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The licensee prepared a report (JAF._RPT MULTI-02903, Revision 0, dated February 13,1998) to justify the proposed extension of surveillance intervals for instrumentation LSFTs, documenting the evaluations required by GL 91-04 and GL 96-01.

3.0 EVALUATION 3.1 Revised LSFT Definition -

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The first proposed change is to revise the LSFT definition to read as follows:

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k A LSFT shall be a test of all required logic components (i.e., all required relays and

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contacts, trip units, solid state logic elements, etc.) of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify operability. The LSFT may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

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The current TS definition of LSFT calls for testing a logic circuit from sensor to activated device.

The current definition further states that the action will go to completion, (i.e., pumps will be started and valves operated). The proposed change eliminates the requirement to test the actuated device and pumps and valves operated as part of the LSFT. Acceptable performance

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of these devices is demonstrated by surveillance testing per other TS requirements, and therefore is not required for LSFT performance. This change is consistent with the improved TS definition given in NUREG-1433, and is, thcrt, fore, acceptable.

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3.1 Extension of Surveillance Intervals 4

h The licensee also proposes to extend the LSFT interval from semiannually to a 24 month

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interval for Primary Containment isolation System (PCIS) instrumentation for all seven functions j

listed in TS Table 4.21, " Core and Containment Cooling System (CCCS)," for the containment i

cooling subsystem and high pressure coolant injection subsystem in TS Table 4.2-2, and i

Radiation Monitoring System (RMS) for the following four functions in Table 3.10-2 of the environmental TS, Appendix B.

1) Reactor Building Area Exhaust Monitors, Recorders, and Isolation

2) Steam Jet Air Ejector (SJAE) Radiation Monitors /Offgas Line Isolation

3) Liquid Radwaste Discharge Monitor / Isolation

4) Standby Gas Treatment System (SBGTS) Actuotion The NRC staff reviewed the licensee's March 30,1998, submittal, and audited the licensee's report JAF_RPT_ MULTI 02903, Revision 0, to evaluate the licensee's justifications for the proposed changes. The licensee evaluated the plant LSFT data collected in the past 22.5 years to establish if any failure of the components that receive the actuation signal involved logic systems that were being tested. The licensee's review identified only two failures out of

3-44 tests on Radiation Monitoring System Instrumentation that involved LSFT. Both failures were of a timer included in the SJAE Radiation Monitor /Offgas Line Isolation Logic. The first failure of the timer was due to the controller time adjustment being set too high. As a corrective action, the controller was manually adjusted to actuate in less time. The second failure of the timer was a blown circuit fuse. The licensee concluded that this was an isolated occurrence with no generic implication. However, based on the drift data, the timer setting had to be lowered in order to extend the LSFT interval from semiannually to once per 24 month. This new setting of the timer was confirmed by the licensee's October 27,1998 letter. No instrument drift for all other systems included in the proposed amendment was addressed since no analog or digital setpoints are involved in those logic systems.

The licensee concluded that, based on the plant historical and maintenance data, the effect on safety of extending LSFT performance interval to once per 24 months is insignificant. The staff agrees with the licensee's conclusion, and finds the proposed changes to the plant TS acceptable.

3.3 Summary Based on the above review and justifications for TS changes, the NRC staff concludes that the licensee has evaluated the proposed TS changes to extend the LSFT performance interval consistent with the guidance of GL 91-04. The staff also finds the proposed LSFT definition to be consistent with the standard given in NUREG-1433. Therefore, the proposed changes are revising the LSFT definition and extending the LSFT performance interval are acceptable.

4.0 STATE CONSULTATION

in accordance with the Commission's regulations, the New York State official wa.s ' otified of the j

n proposed issuance of the amendments. The State official haa no comments.

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5.0 ENVIRONMENTAL CONSIDERATION

1 The amendment changes a requirement with respect to installation or use of a facility

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component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendments involve 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 individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no l

public comment on such finding (63 FR 19978). Accordingly, the 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 the amendments.

6.0 CONCLUSION

The Commission has 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, (2) such activities will be conducted in ' compliance with the I

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. Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: 1. Ahmed Date: Decerber 11,1998 l

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