ML20206F563

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Forwards Safety Evaluation Re Compliance w/10CFR50.62 ATWS Rule Concerning Alternate Rod Injection & Recirculating Pump Trip Sys.Sys Designs Not Completely Acceptable
ML20206F563
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 11/18/1988
From: Labarge D
Office of Nuclear Reactor Regulation
To: Brons J
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
Shared Package
ML20206F567 List:
References
NUDOCS 8811210204
Download: ML20206F563 (3)


Text

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o Novtmber 18, 1988

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-Docket No. 50-333 DISTRIBUTION P Docket: m e d DLaBarge

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EJordan Mr. John C. Brons SVarga BGrimes Executive Vice President, Nuclear Generation B8oger ACRS(10)

Power Authority of the State RCapra CVogan of New York SNewberry JMauck 123 Main Street khite Plains, New York 10601

Dear Mr. Brons:

SUBJECT:

ATWS IMPLEMENTATION STATUS By letters dated June 14, 1985 and October 11, 1985, you submitted your proposed schedule, as required by 10 CFR 50.62(d), for completing the Anticipated Transients Withcut Scram (ATWS) modifications required for the Fit 2 Patrick Nuclear Poi.er Plant. You proposed to implement the required modification by the end of the third refueling outage after the ATWS rule effective date of July 26, 1984. The rule requires that justification be provided for a schedule calling for final implementation later than the second refueling outage after the effective date of the r' ele.

In your June 14, 1985 letter you delineated the major modifications related to the ATWS Rule which were planned for the second refueling cutage following the effective date of the ATWS rule.

Your letter also stated that, because of the total number and scope of modifications planned, and the necessity that the ATWS modifications be performed during an outage, all modifications could not be completed by the end of the 1985 outage. Additionally, your letter of October 11 1985 indicated that the valves comprising the Alternate Rod Injection IARI) System, which will be installed to comply with the ATWS rule, are long lead items with a delivery time of about 50 weeks. Taking into consideration the time required for engineering, design, and material procurement, y w stated that the ARI system could not be installed before the following (1988) refuelinn outage. This was found to be acceptable to the NRC and transmitted to you iri a letter to you dated November 29, 1985.

In your letter of April 15, 1987 you presented information demonstrating confomance with the ATWS Pule.

For the ARI system you supplied a completed checklist from Appendix A of the Safety Evaluation, stated that the requirements for qualification information related to isolation valves contained in Appendix B of the Safety Evaluation will be met and briefly described the separation and testability aspects of the design.

For the Recirculation Pump Trip (RPT) systero you endorsed the BWR Owner's Group position that redundant trip coils in the circuit breaker for each recirculation pump are not required to comply with the ATWS Rule.

In your June 10, 1988 letter you supplied further infomation concerning the ARI and RPT systems. This included an analysis of the ARI and reactor protection system (RPS) separation design to comply with the ATWS Rule h

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l John C. Brons November 18, 1988 1

concerning diversity which led to your position that the ARI meets the diversity requirement and is consistent with the BWR Owner's Group licensing topical report. Since the modificaticrs arc bair.g ::::de during the present refuel outage, you requested an extension of at least one more cycle if the design is considered unacceptable.

The conclusion was also reached in your letter that the RPT breaker design was consistent with the ATWS Rule.

j We have reviewed these submittals and have concluded that the ARI & RPT designs are not completely acceptable. However, we do not believe that these issues are of sufficient safety significance to delay implementation of the ARI system, replace equipment already installed, or driay startup from the present refuel outage.

In order to comply with the ATWS Rule, the ARI system should be provided with instrument components that are diverse from the reactor trip system, the RPT initiation logic should be modified for diversity, and logic i

testing features should be provided before restart folloving the next refueling r,u tage. Our SER, which provides the review details regarding this conclusion is enclosed. Your letter of August 25, 1988 outlining the propored logic testing revisions is under review.

It is expected that it.s previsions will be ir. eluded in a subsequent submittal to address the remaining ARI/RPT issues outlined herein.

Sincerely, or.iginal signed by Nvid L. LaBarge, Project Manager Pro.iect Directorate I-1 Civision of Reactor Projects, I/II

Enclosures:

1. Safety Evaluation
2. Appendix 1 cc: See next page

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DATE :11/\\\\/88

11/17/88
11/H(/88 l

OFFICIAL RECORD COPY

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Mr. John C. Brons Janes A. FitzPatrick Nuclear Power Authority of the State of New York Power Plant CC:

Mr. Gerald C. Goldstein Ms. Donna Ross Assistant General Counsel New York State Energy Office Power Authority of the State

? Empire State Plaza of New York 16th Floor 10 Columbus Circle Albany, New York 12?23 New York, New York 10019 Resident Inspector's Office U. S. Nuclear Regulatory Comission Regional Adniinistrator, Pegion I Post Office Box 136 U.S. Nuclear Regulatory Commission Lycomina, New York 13093 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. Radford J. Converse Mr. A. Klausman Resident Mana er Senior Vice President - Appraisal James A. FitzPatrick Nuclear and Compliance Services Power Plant Power Authority of the State Post Office Box 41 of New York Lycoming, New York 13093 10 Columbus Circle New York, New York 10019 Mr. J Gray, Jr.

Mr. George Wilverding, Manager Directc fuelear Licensing - BWR Nuclear Safety Evaluation Power Authority of the State Power Authority of the State of New York o' New York 123 Main Street 123 Main Street White Plains, New York 10601 White Plains, New York 10601 Fr. Robert P. Jones Supervisor Mr. R. E. Beedle Town of Scriba Vice President Nuclear Support R. D. #4 Power Authority of the State Oswego, New York 13126 of New York 123 Main Street Mr. J. P. Bayne, President White Plains, New York 10601 Power Authority of the State of New York Mr. S. S. Zulla 10 Columbus Circle Vice President Nuclear Engineering New York, New York 10019 Power Authority of the State nf New York Mr. Richard Patch 123 Main Street quality Assurance Superintendent White Plains, New York 10601 James A. FitzPatrick Nuclear Power Plant Mr. R. Burns Post Office Box Al Vice President Nuclear Operations Lycoming, New York 13093 Power Authority of the State of New York Charlie Donaldson, Esquire 123 Main Street Assistant Attorney General White Plains, New York 10601 New York Department of Law 120 Broadway New York, New York 10271