ML20198R024
| ML20198R024 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/28/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20198R018 | List: |
| References | |
| NUDOCS 9901080065 | |
| Download: ML20198R024 (5) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 30686-0001 i
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 249 TO FACILITY OPERATING LICENSE NO. DPR-59 1
POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR FOWER PLANT i
DOCKET NO. 50-333 l.
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1.0 INTRODUCTION
By "JPN-98-028, Forwards Application for Amend to License DPR-59,revising TS Section 3.5.b.1, Main Condenser [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. & Table 3.10-1, Radiation Monitoring Sys That Initiate &/Or Isolate Sys Including Associated Bases|letter dated July 6,1998]], The Power Authority of the State of New York (the licensee) requested a revision to Appendix B Radiological Effluent Technical Specifications (RETSs)
Section 3.5, " Main Condenser Steam Jet Air Ejector (SJAE)" and Table 3.10-1, " Radiation j.
Monitoring Systems that initiate and/or isolate Systems" and the associated bases pages to provide Allowable Outage Times (AOTs) and incorporate administrative and editorial changes.
2.0 BACKGROUND
The licensee performed a review of the RETS as a result of corrective actions associated with License Event Report (98-01)"Partialinvalid Isolations of Reactor Building Ventilation." The licensee determined that performance of certain surveillance and preventative maintenance L
may result in short periods when radiological monitoring equipment is inoperable. During I
these periods, current RETS requires either tripping of the initiation logic associated with the instrumentation to be tested, or entry into the RETS Limiting Condition of Operation (LCO) action associated with the inoperable instrumentation. Entry into the LCO would place the systems associated with the instrumentation in an abnormal configuration during normal plant operations placing additional challenges on the operators. The licensee determined that an amendment was required to provide AOTs for surveillance testing and for repair of selected l
radiation monitoring instrumentation. The proposed AOTs would provide a period of time for selected radiation monitoring instrumentation surveillance testing (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) and repair (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), after which entry into the LCO would be required.
l 3.0 EVALUATION 1-l The licensee proposed the following changes to TS 3.5.b:
Current wording:
b.
Except as specified in 1. below, both SJAE system radiation monitors shall be operable during reactor power operation. The trip time delay setting for jd-closure of the SJAE isolation valve shall not exceed 15 min.
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1.
In the event that one of the two SJAE radiation monitors is made or found to j
be inoperab;e, continued reactor power operation is permissible provided that the inoperable monitor is tripped in the downsecle position.
2.
Upon the loss of both SJAE system radiation monitors, either temporarily monitor radiation levels at the SJAE or initiate an orderly shutdown and have the main steam isolation valves closed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Proposed wording:
b.
Except as specified in 1. and 2. below, both SJAE system radiation monitors shall be operable during reactor power operation. The trip time delay setting for closure of the SJAE isolation valve shall not exceed 15 min.
1.
A channel may be placed in an inoperable status for up to six hours during i
periods of required surveillance without placing the Trip System in the tripped condition provided the other OPERABLE channel is monitoring that Trip Function. Otherwise, in the event that one of the two SJAE radiation monitors is made or found to be inoperable, continued reactor power operation is permissible provided that the inoperable monitor is tripped.
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2.
Upon the loss of both SJAE system radiation monitors, either temporarily monitor radiation levels at the SJAE or initiate ten orderly shutdown and have the main steam isolation valves closed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The licensee proposed change to TS 3.5.b to explicitly include current TS 3.5.b.2 as an j
exception to the requirement that both SJAE radiation monitors be operable during i
reactor power operations is editorialin nature and does not change the intent of the TS.
j The staff finds this change acceptable.
4 The licensee in RETS 3.5.b.1 proposed deleting "in the downscale position." The monitor is still required to be tripped. This will allow the licensee greater flexibility in how to pl3ce a channelin trip. This proposed change does not alter the intent of the specification and is therefore acceptable.
The proposed RETS 3.5.b.1 permits a channel to be Inoperable for up to six hours for periods of required surveillance without placing the trip system in the trip condition provided the other operabia channel is monitoring the trip function. The licensee provides the following justificiation for a six hour surveillance AOT for this instrument:
These radiatior' monitars are arranged in a two-out of-two logic; therefore, both must trip to initiate the required action ( closure of the off-gas isolation valve to the main stack after a time delay). A high radiation condition sensed by the monitor in service would provide sufficient time to take the corrective actions. A six-hour AOT is deemed acceptable for instrumentation in the Reactor Protective System and Emergency Core
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l 3-Cooling System. Therefore, it is appropriate to apply a six-hour AOT to the l
SJAE radiation monitors which are non-safety related. Also, the six-hour l
test duration provides a reasonable amount of time for testing without i
placing undue time constraints on the maintenance personnel.
The staff reviewed the licensee's proposal and agrees that due to the normal actuation l
Lne delay on a receipt of a high radiation signal before the SJAE isolation valves shut, the plant operators will have sufficient time to take the appropriate actions if a real actuation signal occurs. The six-hour period for testing is consistent with the testing period allowed for other instrumentation in the licensee's proposal. Therefore, the staff finds that the six-hour AOT for surveillance testing is acceptable.
l The licensee proposed the following changes to RETS Table 3.10-1, Radiation Monitoring Systems that Initiate and/or isolate Systems:
i incorporated a change to clarify that the column titled " minimum number of operable instrument channels" refers to each trip system. A change was made to note (f) to add LCO 3.1.c (limiting condition for operation) to provide the correct TS reference. The above changes are editorial in nature and do not change the intent of the TS and are l
acceptable to the staff.
l Added a six-hour AOT for surveillance testing and up to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AOT for repair to RETS (Radiation Eff'uent Technical Specification) Table 3.10-1 note a, " Radiation Monitoring Systems that initiate ana/or Isolate Systems" for the Refueling Area Exhaust Monitor, Reactor Building Area Exhaust Monitors, Turbine Building Exhaust Monitors and the Radwaste Building Exhaust Monitors.
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While one channelis out of service for surveillance or repair, the remaining operable l~
channel will monitor the associated parameter and will initiate the required protective l
action if the set point is exceeded. The allowable out of service time of six hours for surveillance testing and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for repair is smallin comparison to the length of a j
normal operating cycle. Therefore, not placing a trip system in the tripped condition for the proposed allovvable out of service time will have a negligible effect on the reliable I
operation of the protective systems and will decrease the likelihood of plant trips, scrams, transients, and challenges to safety systems.
Taking the actions associated with inoperable instruments in RETS Table 3.10-1 during the short testing and repair AOTs (6 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> resoectively) is undesirable. This would place the plant systems associated with the instramentation in abnormal j
configurations during normal plant operations (e.g., secondary containment isolated l
with SGT system in service) placing additional challenges on the Operators.
The six hour AOTs for surveillance testing and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AOT for repair to the above radiation monitors follows the guidance provided in NUREG-1433, " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/4)", Revision 1, dated April 1995. The guidance provided states,
- When a channel is placed in an inoperable j
condition solely for the performance of required surveillance, entry into the associated i
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4 Conditions and Required Actions may be delayed for up to six hours provided the l
associated Function maintains isolation capability." The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> repair AOT for the l
above monitors is in accordance with NUREG-1433 standard. The above changes are l
therefore acceptable to the staff.
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Added note 0) for SJAE radiation monitors to Table 3.10-1. Note 0) references RETS 3.5.b.1 and 3.5.b.2, Main Condenser Steam Jet Air Ejector (SJAE) for minimum number of operable channels requirements. This change is editorialin nature and only provides i
reference to the TS that actually delineates the minimum number of channels required to be operab!:e. The staff finds this acceptable.
l Added note (k) for Main Control Room Ventilation. The note stated th.. 'A channel may be placed in an inoperable status for up to six hours during periods of required surveillance without placing the Trip Function in the tripped condition, or the indicated action shall be taken." The licensee provides the following justification for the six-hour surveillance AOT:
For systems with only one channel ( Main Control Room Ventilation )... a six-hour AOT is being proposed. This is consistent with GE Topical Reports referenced in current TS Bases 4.2 and STS [ Standard Technical Specifications).
The six-hour AOTs for surveillance testing to the above radiation monitor follows the guidance provided in NUREG-1433, " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/4)", Revision 1, dated April 1995. The guidance provided states, "When a channelis placed in an inoperable condition solely for the l
performance of required surveillance, entry into the associated Conditions and Required Actions may be delayed for up to six hours provided the assoc;ated Function maintains isolation capability." The above changes are, themfore, acceptcble to the staff.
The licensee proposed to change 3.1 Gaseous Effluents Monitors Bases to add the following, " Refer to Appendix A Technical Specification Bases 4.2 for references pertaining to surveillance and allowable outage times for selected monitors listed on RETS Table 3.10-1 and Table 3.10-2." The licensee in 3.8 Standby Gas Treatment System Bases, deleted the statement, "The bases given in Appendix A Bases 4.2 for the rod blocks apply here also and were used to arrive at the functional testing l
frequency."
l The licensee's proposed changes to the bases clarifies where the references for AOTs are located and deletes a redundant statement. The proposed change is editorial and
- does not change any license requirement. The staff finds the proposed change acceptable.
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4.0 STATE CONSULTATION
in accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment 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 prev!ously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (63 FR 43211). Accordingly, the amendments meet 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 savironmental 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 %e proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor. John S. Cushing Dato:
December 28, 1998
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