ML20206S279
| ML20206S279 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/15/1986 |
| From: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM TPN-86-41, NUDOCS 8609220154 | |
| Download: ML20206S279 (7) | |
Text
._ _
123 Main Street White Pbns, New York 10601 914 681.6240 E
N i r Vice President Nuclear Generation September 15, 1986 JPN-86-41 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 NUREG-0737 Item III.D.3.4 Control Room Habitability Reauirements
References:
1.
PASNY letter, J.
P.
Bayne to T. A.
- Ippolito, dated August 13, 1981 (JPN-81-60) regarding Control Room Habitability Requirements.
2.
NYPA letter, J.
P.
Bayne to D.
B. Vassallo, dated l
June 9, 1982 (JPN-82-50) regarding post-TMI requirements and Generic Letter 82-10.
3.
NRC letter, D.
B. Vassallo to L. W.
- Sinclair, dated March 14, 1983 issues confirmatory order regarding commitments on post-TMI related issues.
Dear Sir:
The Authority submitted a report comparing the FitzPatrick Control Room Ventilation System with the criteria in NUREG-0737 Item III.D.3.4
" Control Room Habitability Requirements" (Reference 1).
As a result of this evaluation, the Authority committed to upgrade the ventilation system with four improvements.
One of these improvements was to install a redundant damper to preclude loss of the ventilation system in the event the existing damper failed to open.
This new damper would be installed in parallel with damper MOD-113, an existing damper.
The Authority subsequently restated this commitment in Reference 2.
P Ik l
r The NRC issued an order confirming the Authority's commitments on eight NUREG-0737 items as an attachment to Reference 3._-This Order confirmed the Authority's schedule for completing modifications associated with control room habitability (NUREG-0737 Item III.D.3.4) referred to in Reference 2.
Three months after the Order was issued, the Authority performed a test of the Control Room Ventilation System.
Specifically, damper MOD-113 was tested to determine if a single active failure of this damper could degrade or prevent the system operation.
The test demonstrated that the single active failure of damper MOD-113 would not result in loss of the system's functional performance.
Based on the results of this test, the Authority concluded the the ventilation system was in compliance with NUREG-0737 Item III.D.3.4 and no need existed to add a redundant damper as described in References 1 and 2.
The Authority was in full compliance with this NUREG-0737 item on the date specified in the NRC order.
The NRC Resident Inspector at FitzPatrick requested that additional information on this test and its results be provided i
to the NRC for eview.
Attached is a summary of the test and its results.
Should you or your staff have any questions regarding this matter, please contact Mr. J. A. Gray, Jr. of my staff.
Very truly yours, J $n C.
rons l
Senior Vice President Nuclear Generation l
cc: Office of the Resident Inspector U.
S.
Nuclear Regulatory Commission P. O.
Box 136 Lycoming, New York 13093
r
.o to JPN-86-41 NEW YORK POWER AUTHORITY JAMES A.
FITZPATRICK NUCLEAR POWER PLANT Additional Information Regarding NUREG-0737 Item III.D.3.4 - Control Room Habitability I.
Introduction and Background The Authority prepared a report comparing the FitzPatrick Control Room Ventilation System with the criteria in NUREG-0737 Item III.D.3.4, " Control Room Habitability Requirements", and submitted it to the NRC as an attachment to Reference 1.
Reference 1 also included a description of the FitzPatrick Control Room Ventilation System.
Item III.D.3.4 of NUREG-0737 references Standard Review Plan (SRP) Section 6.4,
" Control Room Habitability System" as the source of criteria.
One criterion of SRP 6.4 is that "a single failure of an active component should not result in the loss of system's functional performance."
As a result of this comparison, the Authority committed to upgrade the FitzPatrick Control Room Ventilation System and implement four improvements (Reference 1).
One of these improvements was the installation of a new redundant damper in parallel with MOD-113, an existing damper.
(MOD-113 is the Control Room Ventilation System emergency outside air intake damper.
See Figure 1, page 4 of the attachment to Reference 1.)
This modification was proposed to preclude the loss of the ventilation system's functional performance due an active failure of this damper.
This is the only instance where the FitzPatrick Control Room Ventilation System was thought not to comply with the single failure criterion.
A new damper and associated ductwork were proposed.
The new damper would be installed in parallel with damper MOD-113 to provide an alternate flow path for outside air.
This new damper was to have been powered from a safety related power supply.
The Authority subsequently restated this commitment in Reference 2.
l The NRC issued a Safety Evaluation as an attachment to Reference 4 approving the modifications proposed by the I b
F:
Authority.
The Safety Evaluation concluded that the proposed modification satisfied control room habitability requirements and was therefore acceptable.
Item III.D.3.4 was considered complete.
An NRC Order confirming the Authority's commitments on eight NUREG-0737 items was issued in March 1983 as an attachment to Reference 3.
This Order confirmed the Authority's schedule for completing ^the FitzPatrick Control Room Ventilation System modification.
II. Damper Test Summary Shortly after the Authority submitted the Control Room Habitability Report to the NRC, additional research identified that the existing damper (MOD-113) was designed to be single active failure proof.
Therefore, it could fail-closed (i.e. cause a loss of the system's functional l
performance) only if the mechanical linkage from the electro-hydraulic actuator to the damper were broken.
The Authority performed a test of the Control Room Ventilation System in June of 1982.
Specifically, MOD-113 was tested to determine if a single active failure of this damper would prevent the system's function.
The test demonstrated that a single active failure of damper MOD-113 would not render the Control Room Ventilation System inoperable.
Damper MOD-113 is a balanced damper and is equipped with a spring-actuated, fail-open operator.
The spring retracts the actuator shaft in the event power is lost to the damper, thereby assuring that the damper is in the open position.
Damper MOD-113 is also equipped with a spring action which opens the damper approximately ten percent should the actuator linkage break.
During the test, the actuator linkage was disconnected to simulate a mechanical break.
The ventilation system was placed in the " isolate mode" with the supply fans running.
Air flow across the damper kept damper MOD-113 open.
The damper was then manually forced closed.
Differential pressure across the damper re-opened the damper when manual pressure was released.
The suction head developed by the fans was not sufficient to draw the disconnected damper MOD-113 closed.
This confirmed that damper MOD-113 is balanced and will fail open even if the actuator linkage is broken.
l.
During the test, the control room was pressurized to 0.26 inches of water with full flow through damper MOD-113 and no flow through damper MOD-114.
Based on the results of this test, the Authority did not add a redundant damper as described in References 1 and 2 because it was not necessary to comply with the criteria of NUREG-0737 Item III.D.3.4.
III. NRC Notification The NRC was notified in writing of the Authority's decision not to complete this modifications on two occasions.
1.
In June of 1982, Reference 2 incorporated the completion of the Control Room Ventilation System damper modifications into the FitzPatrick Integrated Schedule.
Reference 5 was the April 1983 submittal of Revision 5 of the FitzPatrick Integrated Schedule.
On sheet 1 of 2, this modification, labeled " Control Room Habitability * - (Futher tests have shown no mod req'd)", was marked " COMP" - i.e.
complete.
(The asterisk denoted an " Extension to Previous commitment or request for extension to NRC schedular requirement.")
- 2. Reference 4 was the Authority's annual submittal of a summary of modification, changes and tests implemented at FitzPatrick during 1982 as required by 10 CFR 50.59.
Safety Evaluation JAF-SE-82-045 (on page 14 of 22) describes Operability Test 70A.
Operability Test 70A determined that failure of damper MOD-113 would not render the Control Room Ventilation System inoperable.
The NRC was also informed orally of this change.
The NRC was informed of the Authority's plans not to install a second redundant damper in an August 1983 conversation between Mr. J. A. Gray, Jr. of my staff and the NRC Project Manager, Mr. J. Hegner.,
m_
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r
.~
Notes and
References:
1.
PASNY letter, J.-P.
Bayne to T. A.
Ippolito, dated August 13, 1981 (JPN-81-60) regarding Control Room Habitability Requirements.
Transmitts " Control Room Habitability Evaluation" in response to NUREG-0737 Item III.D.3.4.
Commits to install a redundant damper in parallel with MOD-113 by January 1, 1983.
2.
NYPA letter, J. P. Bayne to D.
B. Vassallo, dated June 9, 1982 (JPN-82-50), regarding post-TMI Requirements, Generic Letter 82-10.
Attachment refers to JPN-81-60 and to FitzPatrick Integrated Schedule.
Integrated Schedule states that modifications will be completed by the end of the 1983 outage.
- 3. NRC letter, D.
B. Vassallo to L. W. Sinclair, dated March 14, 1983 issues confirmatory order regarding commitments on post-TMI related issues. " Licensee's Commitments on Appliciable NUREG-0737 Items from Generic Letter 82-10" requires that facility be modified "as identified by licensee study", " prior to start of Cycle 6 (7/83)."
Identifies six PASNY letters (JPN-82-38, 50, 68, 70, 71 and 91) as the basis for the order.
- 4. NRC letter, D.
B. Vassallo to L. W. Sinclair, dated February 24, 1982 regarding NUREG-0737 Item III.D.3.4 Control Room Habitability.
Includes NRC Safety Evaluation for FitzPatrick from the Accident Evaluation Branch.
Safety evaluation finds proposed modifications acceptable.
5.
PASNY letter, J.
P.
Bayne to H. R.
Denton, dated April 12, 1983 (JPN-83-32) regarding integrated schedule for plant modifications.
Transmitts Revision 5 of Integrated Schedule.
6.
NYPA Safety Evaluation JAF-SE-82-045, "Special Stroke Test of 70 MOD-113", test OT-70A dated June 15, 1982.
1 7.
PASNY letter, C. A. McNeill, Jr. to J. A. Allen, dated May i
13, 1983 (JAFP-83-0513) regarding annual summary of FitzPatrick plant modifications, changes and experiments I
for 1982.
Safety Evaluation JAF-SE-82-045 (p.14 of 22)
I describes special Operability Test 70A.
Operabilty Test 70A was a test of Control Room Ventilation System outside air damper MOD-113.
8.
PASNY memorandum, G. A. Jacoboson to V. Walz, dated June l i 4
l
r-21, 1982 (TS 201) regarding Modification F1-81-041.
Describes design basis for Control Room Ventilation System and concluded, based on the results of Special Stroke Test OT-70A, that a redundant damper is not necessary.
Documents PORC review of Operability Test 70A.
- 10. PASNY memorandum, J. Van Name to R. Ram, dated June 24, 1986 (DPPS/JVN/2010/82/118) regarding FitzPatrick Control Room Habitability Modification.
Describes test performed June 17, 1982 of damper MOD-113.
Concludes that there is no need to perform modification.
- 11. PASNY memorandum, L. Guaquil to C. A. McNeill, Jr., dated July 2, 1982 ([[::JAF-82-115|JAF-82-115]]) regarding Control Room Habitability, NUREG-0737,' Item III.D.3.4, Single Failure Criterion, MOD-113.
Concludes that second redundant damper is not required to comply with NUREG-0737 Item III.D.3.4.
Includes Nuclear Safety Evaluation ESE-82-002-70
" Nuclear Safety Evaluation for NUREG-0737, Item III.D.3.4, Single Failure Criterion for JAF Control Room Habitability."
- 12. NYPA letter, J.
C.
Brons to D. R. Muller, dated April 15, 1982 (JPN-86-18) regarding proposed change to the Technical Specifications regarding Main Control Room Emergency Ventilation Air Supply System Capacity Test (JPTS-82-01).
- 13. NRC Inspection Report 50-333/86-05, S. M. Collins to R. J.
Converse, dated July 21, 1986.
Opens item 333/86-05-01 regarding proposed modification of FitzPatrick Control Room Ventilation System and TMI Action Plan Item III.D.3.4..