Text

Proposed Tech Specs,Revising Table 3.7-1 to Reflect Four Mods to Be Installed During 1988 Refueling Outage,Including Primary Containment Radioactivity Monitoring Sys & Svc & Breathing Air Supplies to Drywell
	ML20207F101
Person / Time
Site:	FitzPatrick
Issue date:	08/10/1988
From:	; POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	;
Shared Package
ML20207F004	List: JPN-88-040, Forwards Application for Amend to License DPR-59,revising Tech Specs Table 3.7-1 to Reflect Mods to Be Installed During 1988 Refueling Outage,Including Primary Containment Radioactivity Monitoring Sys.Fee Paid; ML20207F024; ML20207F101;
References
	NUDOCS 8808180216
	Download: ML20207F101 (19)
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.

,,- i Attachment I r

PROPOSED TECHNICAL SPECIFICATION CHANGES l REGARDING CONTAINMENT ISOLATION VALVES TABLE 3.7-1 (JPTS-88-001) r r

f NEW YORK POWER AUTHORITY James A. FitzPatrick Nuclear Power Plant .

Docket No. 50-333 DPR-59 h

s-8908180216 800810 DR ADOCK 0 % g3 ,

. . _ . . . . . .. _ - . - - - - - - ~ . _ . . _ - _ . . - . _ . - _ - . . . . . . - . ~ - . . . . _ . _ .

JAFirP .

Table 3.7-1 (Cont'd)

PROCESS PIPELI[I PENETRATING PRIMRY CONTAllsENT *

(Nebers in parentheses are keyed to numbers on following pages: signal codes are If sted on following pages)

Power Location Power Closing Drywell Valve Type to Open Ref. to to Close Isolation Time Nome 1 Remarks and.

l Line Isolated Penetration (6) (5) (6) Group Drywell (5) (6) Signal (7) Status Exceptions Male Steam Line I-7A,8,C.D A0 Globe Air and A Inside Air and 8,C.D,P E Note (1) Open l

AC PC spring l Main Steam Line I-7A,8,C,0 A0 Globe Air and A Outside Air and 8,C.D.P.E Note (1) Open AC, DC spring main Steae Line I-8 MD Gate AC A Inside Ac 8,C,D P.E 15 see Closed l

Drafo l

l Male Steam Line I-8 M0 Gate DC A- Outside DC 8,C.D.P.E 15 see Closed l Drals l From Reactor I-9A, 3 Check - A Outside Process Rev. flow NA Open l Fee 6ater i

I Free Reactor I-9A, B Check - A Inside Process Rev. flow NA Open Feedwater I-41 50 Valves AC A Inside Spring b,C E Open Saaple I Reector Water Reector Water Saaple I-41 50 Valves AC A Outstde Spring 8,C M Open

! Control Rod Hy- I-36 Check - A Inside Process Rev. flow NA) desulfc Return

, Control Rod Hy- I-36 Check - A Inside Process Rev. flow NA) Opens on Rod t

draulic Return ) movement and

) closed at all

) other times Note (4)

)

l Control Rod I-36 50 Valves Air and A Dutside Spring Note (4) M) l Dr1ve Exhuast AC )

i )

l )

l Control Rod I-38 SO Valves Air and A Outside Spring Note (4) NA)

Drive Exhuast AC )

)

, Control Red I-37 50 Valves Air and A Outside Spring Note (4) NA)

I Drive Inlet AC )

I )

l Centrol Red I-37 50 Valves Air and A Outside Spring Note (4) NA)

I Drive Inlet AC )

Amendment No.)NM i ,8

JAFNPP ,

Tablo 3.7-1 (Cont'd) -

PROCESS PIPELINE PENETRATING PRIpWUtY CONTA!WENT (Numbers in parentheses are key?d to numbers on following pages: signal codes are listed on following pages) .

Power Location Power Closing Drywell Valve Type to Open Ref. to to Close Isolation Time Normal Remarks and Line Isolated Penetration (6) (5) (6) Group Drywell (5) (6) Signal (7) Status Exceptions M121-purge to X-31Ac l rectre pump X-31Bc SO Valve Ac C Outside Spring B F,'!M Not applicable Open Mist-purge to I-31Ac recirc pump X-318e Check Process C Inside Process Rev. flow Not appifcable Open RHR Reactor Shut-M Cooling supply A-12 M0 Gato De A Outside Dc A,U.F.RM 38 Sec Closed RHR Reactor Shut-down Cooling supply X-12 MD Gate Ac A Inside Ac A,U,F RM 38 Sec Closed RHR to Suppression Throttiing Type Spray Header X-211A,8 M0 Globe Ac B. Outside Ac G.S.RM 10 Sec Closed Valve Note (2)

RHR - Containment Specy X-39A M0 Gate Ac 8 Outside Ac G.5,RM 10 Sec Closed Note (2)

RNR - Containment Throttling Type Spray X-39A MD Globe Ac 8 Outside Ac 10 Sec Closed G.S.RM Valve Note (2)

RHR - Containment Spray X-398 M0 Gate Ac 8 Outside Ac G,5,RM 10 Sec Closed Note (2)

RNR - Containment Throttling Type Spray X-399 M0 Globe Ac 8 Outside Ac 10 Sec G.S.RM Closed Yalve Note (2)

RHR - Reactor Head Spray X-17 M0 Gate Ac A Instde Ac A.U,F.RM 20 Sec Closed RMR - Reactor Head Spray X-17 MD Gate De A Outside De A U.F.RM 20 Sec Closed RNR to Suppression Throttling Type Pool X-210A,8 M0 Globa Ac 8 Outside Ac G RM 70 Sec Closed Yalve Note (2)

RNR - LPCI to Reector X-13A,8 M0 Gate Ac A Outstde Ac RM 120 Sec Closed Note (10)

RHR - LPCI to Throttling Type Reector X-13A,3 M0 Globe Ac A Dutside Ac RM 90 Sec Open Valve Note (10)

RNR - LPCI to Testable check Reector X-13 A,8 A0 Check -- A Inside Process Rev. flow Not appif cable Closed Valve (3.16) eMR pump section fran suppress 1on pool X-225A,8 M0 Gate Ac 8 Outside Ac RM Not applicable Open Ameadment No. pf, pf, 3s6 199

_ ,.=-. -._ . . . - , _ . .- - _ _ , _ , . ,- . _ _ _ ~ _ ,. -. _- ._ . - .-.

JAFIFp

Table 3.7-1 (Cont'd)

PROCESS PIPELINE PENETRATIIIG PRIMILRY CONTAINDENT (Numbers in parentheses are keyed to numbers on followfog pages: signal codes are If sted on following pages)

Fower 3_ocation FO-er closing Drywell valve Type to Open Ref. to to Close Isolation Time Reserks and ,

Line Isolated teormal Penetration (6) (5) (6) Group Drywell (5) (6) Signal (7) Statu: Exceptions HPCI - Turbine closes on Rev.

Eshaust I-214 Check Fwd flow flow or low B Outside Process Rev. flow Not appifcable Open exhaust presserc IFCI - Turbine Es: horst X-214 Check Fed flow Outstde Process B Rev. flow Not appifcable Open NPCI - Pump suction X 226 M0 Gate Dc 5 Outside DC L.RM ' lot appifcable Closed HPCI - Pump suction I-226 M0 Gate Dc 8 Outside Dc L.RM slot applicable Closed IFCI . Pump Discha rge X-93 MD Gate Dc 8 Outside Dc RM loot appifcable Closed IPCI - Turbine Exhaust Draf n X-222 Stop Check Fwd flow B Outside Process Rev. flow Not applicable Closed HPCI - M!nferi Pump Flow X-2108 Check Fwd flow 8 Outside Process Rev. flow Not applicable Closed HPCI - Mfnfmue Pump Flow X-2108 M0 Globe Dc 8 Outstde Oc L.RM 10 sec Closed DRYWELL ATMOSPHERIC CONTROL AND SERVICES I:;strument Af r to Drywell X-22 Check Process C Inside Process Rev. flow Not appifcable Open Icstrument Air to Fall in open

~ Drywell I-22 50 Valve Spring C Outside Ac RM slot appitcable Open posttion to g ensure adequate Drywell Purge Inlet I-25. I-71 A0 Butterfly Af r/Ac 8 pneumatic supply Outside sprf ag F.A.Z RM S see Closed Drywell Purge Inlet X-25. I-71 A0 Butterfly Af r/Ac B Outside Spring F.A.Z RM 5 sec Closed Drywell Main E:.houst 1-26A 8 A0 Butterfly Af r/Ac 8 Outside Spring F.A.Z RM 5 sec Closed Amendment No. g g. [ 1 [

JAFNPP

l -

Table 3.7-1 (Cont'd)

PROCESS PIPELINE PENETRATING PRIMARY CONTAINENT -

(Numbers in parentheses are keyed to nou6ers on following pages: signal codes are If sted on following pages) l t

Power Location Power Closfng Drywell Valve Type to Open Ref. to to Close Isolation Time Normal Remarts and Line Isolated Penetration (6) (5) (6) Group Drywell (5) (6) Signal (7) Status Exceptions CAD Supply to ) Fall in open Instrument Air to ) position to Drywell X-57c SO Valve Spring C Outside Ac RM Not appilcable Open ) ensure adequate

) pneumatic supply CAD Supply to Instrument Air to Drywell X-57c Check Process C Inside Process Rev. flow Not appif cable Closed Drywell Atmosphere Seg12 Supply X-31Ad 50 Valve Ac 5 Outside Spring F.A,Z,RM Not applicable Open Drywell Otmosphere Sam 12 Supply X-318d 50 Valve Ac B Outside Spring F.A Z,RM Not appif cable Open Drywell Atmosphere See12 Return X-52a 50 Valve Ac B Outside Spring F.A,Z,RM Mot appilcable Open Drywell Atmosphere Sa w12

_ Return X-55b SO Yalve Ac B Outside Spring F.A,Z,RM Not appif cable Open amendmentNo-#,pCJmf 205

Attcchm nt II HEW YORK POWER AUTHORITY James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 DPR-59 Safety Evaluation for Technical l Specification Chances Recardina Containment Isolation valves (J PTS -8 8 -001 )

I. DESCRIPTION OF THE PROPOSED CEANGES This applications proposes to revise pages 198, 199, 202 and 205 of Table 3.7-1 ("Process Pipeline Penetrating Primary Containment") of the James A. FitzPatrick Nuclear Power Plant Technical Specifications to reflect four modifications which will be installed during the 1988 refueling outage, currently scheduled for August 1988. These modifications involve drywell radiation monitors, service and breathing air supplies to the drywell, and Reactor Water Sample and Residual Heat Removal system containment isolation valves.

Changes (a) and (d) add two missing table entries.

Primary Containment Radioactivity Monitorina System. (Gaseous and Particulate)

Four new entries are added to page 205 of Table 3.7-1:

(a) Line isolated is "Drywell Atmosphere Sample Supply";

Drywell Penetration is "X-31Ad"; Valve type is "SO Valve"; Power to Open is "Ac"; Group is "B"; Location Relative to Drywell is "Outside"; Power to close is

, "Spring"; Isolation signal is "F, A, Z, RM"; closing j time is "Not Applicable"; and Normal Status is "Open."

There are no Remarks and Exceptions.

(b) Line isolated is "Drywell Atmosphere Sample Supply";

Drywell Penetration is "X-31Bd"; Valve type is "So Valve"; Power to Open is "Ac"; Group is "B"; Location Relative to Drywell is "Outside"; Power to Close is "Spring"; Isolation signal is "F, A, Z, RM"; Closing time is "Not Applicable"; and Normal Status is "Open."

There are no Remarks and Exceptions.

(c) Line isolated is "Drywell Atmosphere Sample Return";

Drywell Penetration is "X-52a"; Valve type is "SO

Valve"; Power to Open is "Ac"; Group is "B"; Location Relative to Drywell is "Outside"; Power to Close is "Spring"; Isolation signal is "F, A, Z, RM"; closing time is "Not Applicable"; and Normal Status is "Open."

There are no Remarks and Exceptions.

Attachm:nt II l

[d) Line isolated is "Drywell Atmosphere Sample Return";

Drywell Penetration is "X-55b"; Valve type is "So l Valve"; Power to Open is "Ac"; Group is "D"; Location Relative to Drywell is "Outside"; Power to Close is '

"Spring"; Isolation signal is "F, A, Z, RM"; closing time is "Not Applicable"; and Normal Status is "Open." -

There are no Remarks and Exceptions.

Service and Breathina Air Sucolies to Drywell Four entries are deleted from page 202 of Table 3.7-1:

(e) Line isolated is "Service Air to Drywell"; Drywell Penetration is "X-21"; Valve type is "Check"; Power to Open is "Process"; Group is "C"; Location Relative to Drywell is "Inside"; Power to Close is "Process";

Isolation signal is "Rev. Flow"; Closing time is "Not Applicable"; and Normal Status is "Closed." There are no Remarks and Exceptions.

(f) Line isolated is "Service Air to Drywell"; Drywell Penetration is "X-21"; Valve type is "Hand Gate"; Power to Open is "Hand"; Group is "C"; Location Relative to Drywell is "Outside"; Power to Close is "Hand";

Isolation signal is "- "; Closing time is "Not Applicable"; and Normal Status is "Closed." There are no Remarks and Exceptions.

(g) Line isolated is "Breathing Air to Drywell"; Drywell Penetration is "X-61"; Valve type is "Check"; Power to Open is "Process"; Group is "C"; Location Relative to Drywell is "Inside"; Power to Close is "Process";

Isolation signal is "Rev. Flow"; Closing time is "Not Applicable"; and Normal Status is "Closed." There are no Remarks and Exceptions.

(h) Line isolated is "Breathing Air to Drywell"; Drywell Penetration is "X-61"; Valve type is "Hand Gate"; Power to Open is "Hand"; Group is "C"; Location Relative to Drywell is "Outside"; Power to Close is "Hand";

Isolation signal is "- "; Closing time is "Not Applicable"; and Normal Status is "Closed." There are no Remarks and Exceptions.

Residual Heat Removal System Valve.ChADSA on page 199, two table entries for drywell penetrations X-39A and X-39B ("RHR - Containment Spray") are replaced with four entries. The four new entries aret (1) Line isolated is "RHR - Containment Spray"; Drywell Penetration is "X-39A"; Valve type is "MO Gate"; Power Attacha nt II to Open is "Ac"; Group is "B"; Location Rolative to Drywell is "Outside"; Power to Close is "Ac"; Isolation signal is "G,S,RM"; Closing time is "10 Sec"; and Normal Status is "Closed." Remarks and Exceptions is "Note (2)."

(j) Line isolated is "RHR - Containment Spray"; Drywell Penetration is "X-39A"; Valve type is "MO Globe"; Power to Open is "Ac"; Group is "B"; Location Relative to Drywell is "Outside"; Power to Close is "Ac"; Isolation signal is "G,S,RM"; closing time is "10 Sec"; and Normal Status is "Closed." Remarks and Exceptions is "Throttling Type Valve Note (2)."

(k] Line isolated is "RHR - Containment Spray"; Drywell Penetration is "X-39B"; Valve type is "MO Gato"; Power to Open is "Ac"; Group is "B"; Location Relative to Drywell is "Outside"; Power to Close is "Ac"; Isolation signal is "G,S,RM"; closing time is "10 Sec"; and Normal Status is "Closed." Remarks and Exceptions is "Note (2)."

(1) Line isolated is "RHR - Containment Spray"; Drywell Penetration is "X-39B"; Valve type is "MO Globe"; Power to Open is "Ac"; Group is "B"; Location Relative to Drywell is "Outside"; Power to Close is "Ac"; Isolation signal is "G,S,RM"; Closing time is "10 Sec"; and Normal Status is "Closed." Remarks and Exceptions is "Throttling Type Valve Note (2)."

> Reactor Water Samole Containment Isolation Valves Two "Reactor Water Sample" line entries on page 198 of Table 3.7-1 are revised as follows:

(m) For the valve location relative to drywell "Inside,"

Valve Type is changed from "AO Globe" to "SO Valves" and Power to Close is changed from "Air and AC" to "AC."

(n) For the valve location relative to drywell "Outside,"

the Valve Type is changed from "AO Globe" to "SO Valves" and Power to close is changed from "Air and AC" to "AC."

II. PURPOSE OP THE PROPOSED CKANGES This application proposes to revise Table 3.7-1 ("Process Pipeline Penetrating Primary Containment") of the James A.

FitzPatrick Nuclear Power Plant to reflect four modifications which will be installed during the 1988 refueling outage, currently scheduled for August 1988. The modificatiens are described below.

2

! Attachmant II i

Primary Containment Radioactivity Monitors Chances fal-Id1 l

j As described in Section 5.2 of the FitzPatrick Updated Final 1 Safety Analysis Report (FSAR), FitzPatrick has redundant primary i containment radioactivity monitors. PCRMS instruments monitor l both gaseous and particulate radioactivity levels during normal 3

plant operation. A single pair of supply and return lines i currently service both monitors (i. e., both monitors draw primary containment (drywell? atmosphere through a single supply line and exhaust through a sLngle return line.)

Limiting conditions for operation (LCOs) for the particulate j and gaseous portions of PCRMS are included in Section 3.6.D.6

) (page 142) of the FitzPatrick Technical Specifications.

l The Authority is installing a second pair of PCRMS sample i lines to improve system reliability. When this modification is complete, each PCRMS monitor will have its own supply and return lines (penetrations X-31Ad, X-31Bd, X-52a and X-55b.) This

, modification will eliminate the possibility that both monitors j could be inoperable due to a single line failure.

! This proposed change also adds two containment penetrations (X-31Ad and X-55b) to Table 3.7-1 for the existing pair of PCRMS sample lines. These two lines are not currently included in Table 3.7-1. Figure 5.2-9 ("Drywell and Suppression Chamber Inerting and Purge System l

Updated FSAR shows the exis(Sheet 3 of 5)") of the FitzPatrick ting arrangement.

4 As part of this modification, some existing valves will be moved to the new line. This is being done to meet separation l criteria for the valve's power supplies. In a few cases, valves

! will be assigned new tag numbers. When the modification is j complete, the following arrangement will exist:

Penetration Function Valves

!' X-31Ad Existing Supply 27SOV-135A and 27SOV-135C X-55b Existing Return 27SOV-125B and 27SOV-125D

, X-31Bd New Supply 27SOV-135D and 27SOV-135B i X-52a New Return 27SOV-125C and 27SOV-125A l

l The FitzPatrick FSAR will be revised to reflect this new l arrangement.

Service and Breathina Air Sucolies to Drvvell, Chanaes rel-rh1 Pipe lines associated with containment penetrations X-21 and X-61 (breathing air and service air, respectively) will be cut and capped during the 1988 refueling outage.

These penetrations were designed and installed to supply breathing and service air for personnel and equipment in the

i

Attcchment II j

l drywell during maintenance. In practice, these pipe lines are not used. Rather, portable air supplies are used.

i Residual Heat Removal System Valve. Chances til - fil Two RHR system motor-operated gate valves (10 MOV-31A and 10 MOV-31B) will be replaced with motor-operated globa valves during the upcoming refueling. The replacement of these valves will increase the degree of control an operator has over containment spray flow rate.

Analyses performed in support of BWR Owners' Group Emergency 4 Procedures (EOPs) have identified that it may be desirable to throttle containment spray flow (e.g. limit or reduce containment spray flow) during certain accident conditions. ,

The flow characteristics of gate valvos make them unsuitable for flow throttling. Globe valves are suitable.

This modification will permit throttled containment spray flows.

Maximum spray flow is also reduced.

Reactor Water Samole Isolation Valves. Chances fn1 - fn1

Two Reactor Water Sample globe valvos (02-2AoV-39 and 1

02-2Aov-40, associated with penetration X-41) will be replaced j with solenold-operated valves (02-2SOV-39 and 02-2SOV-40). The existing globe valves were opened using pneumatic air pressure and electrical AC power. The new solenoid valves will use AC

] power only.

i These globe valves are being replaced to comply with the Authority's commitments (Reference 1) regarding post-accident instrumentation and Regulatory Guide 1.97 Rev. 2. The new !

solenoid-operated valves will provide environmentally qualified, positive valve position indication.

III. IMPACT OF THE PROPOSED CHANGES Applicable portions of Regulatory Guide 1.97 Revision 2,

("Instrumentation For Light-Water-Cooled Nuclear Power Plants To Assess Plant and Environs Conditions During and Following An Accident,") were implemented as part of these modifications, j (See Reference 1.) ;

Applicable portions of NUREG-0737, Item II.E.4.2, ,

"Containment Isolation Dependability," (Reference 2) were also l considered. NUREG-0737, Item II.E.4.2 referenced portions of ;

Background

l l

As described in FSAR Section 4.8, the RHR system has nine modes of operation. During initial phases of a LOCA (loss-of-coolant accident), RHR operates in its low-pressure l coolant injection (LPCI) mode to restore and maintain reactor

! vessel water level. The containment spray mode is an integral l part of the RHR system and is used to reduce drywell pressure l during the later phases of a LOCA. It is not used during the initial phases of a design basis LOCA.

Containment Integrity (Large-Break LOCA Analysis)

FSAR Section 14.6.1.3.3 evaluates long-term primary l containment response to a LOCA and how containment spray affects

! response. Four cases ( A - D) were considered. One core spray loop was assumed to operate in all four cases. In three of the l cases (A, B and C), RHR was switched from LPCI (low-pressure l coolant injection) mode to containment cooling approximately 10 minutes after the start of the accident. (Considerable time is

, available to place the RHR system in containment cooling mode l because maximum allowable containment pressure will not be l

reached until approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the start of the accident.)

j Attachmsnt II In case D, containment spray was not operated to reduce containment temperature and pressure. Case D conservatively assumes the operation of the following RHR system components: one RHR loop with one RHR (of four) pump, one RHR heat exchanger and two service water pumps.

FSAR Figures 14.6-6 through 14.6-8 (and Tables 14.6-1 and 14.6-2) summarize containment response for these fotr cases.

FSAR Figure 14.6-8 shows containment pressure versus time for the four cases.

These analyses show that even without containment sprays (zero flow), peak containment pressure and temperature remain within allowable limits during a design basis LOCA. (Containment design pressure is 56 psig; design temperature is 309 degrees F.)

Therefore, the reduction in containment spray flow resulting from replacement of gate va'ves with globe valves is acceptable and is bounded by accident unalysis which assume no containment spray flow.

Environmental Qualification (EQ)

A FitzPatrick-specific, EQ analysis was performed in Reference 8. This analysis determined the maximum allowable temperatures for equipment inside the drywell to meet EQ requirements.

A containment spray flow rate of 1800 gpm has been analyzed (Reference 5) and will maintain the drywell temperature within acceptable EQ limits. The new maximum containment spray flow rate of 6700 gpm is signiricantly greater than the 1800 gpm required for EQ.

Chugging An analysis of small and intermediate break LOCA (Reference

5) states:

"all of the conditions necessary for chugging do not occur during operation of the drywell sprays at either 1800 or 7000 gpm. Therefore the duration and magnitude of chugging loads...are unaffected by the changes in the drywell spray system."

Emergency Operating Procedures Emergency Operating Procedures (EOPs) require operation of l containment sprays to maintain drywell temperature and pressure below their design values.

Current FitzPatrick EOPs limit the combined spray flow rate of both RHR loops to less than 10,000 gpm. The installation of throttling type valves will enhance to operator's ability

Attachment II to limit spray flow to this value. This modification will not prevent a combined spray flow rate of 10,000 gpm from being attained.

Raactor Water Samole Containment Isolation Valves, Chances imi - In1 These valves are used to draw a small sample of reactor water for analysis. They are normally open to provide flow to the crack arrest verification subsystem of the hydrogen water chemistry system. The isolation signals used to actuate these valves are not changed by this modification.

The change from an air-operated valve to a solenoid-operated valve will not affect the valve's ability to perform its intended design function in the event of an accident. Since the new valves will require only AC power to open, overall reliability should be improved. The existing valves require both electrical and pneumatic energy te open. The new valves use spring power to close as do the existing valves.

Environmentally qualified positive valve position indication will ensure the operator's ability to confirm primary containment isolation in the event of an accident.

Regulatory Guide 1.97, Revision 2 (Table 1) lists the purpose of primary containment isolation valve position indication as "accomplishment of isolation." Primary containment isolation valve position is a Type B variable which is defined as "variables that provide information to indicate whether plant safety functions are being accomplished." This modification satisfies this criteria.

Regulatory Guide 1.97 also classifies primary containment isolation valve position as Category 1. Design and qualification criteria specified in the guide for Category 1 instrumentation are the most restrictive. The guide specifies environmental, seismic, redundancy, power supply, quality assurance, display and recording criteria for Category 1 instruments. These new valves satisfy Category 1 criteria as described in Reference 1.

IV. EVALUhTION OF SIGNIFICANT HAEARDS CONSIDERATIONS Similar Examples In the April 6, 1983 FEDERAL REGISTER (48FR14870), the NRC published examples of license Amendments that are not likely to involve significant hazards considerations. Example number (vii) of that list is applicable to these proposed changes (except changes (a) and [dj) and states:

I

Attachment II "A change to make a license conform to chari < s in regulations, where the license results in very minor changes to facility operations clearly in keeping with the regulations."

Changes [a) and (d) are similar to example number (i) which states:

"A purely administrative change to the Technical l Specifications: for example,... correction of an error."

l l Sionificant Hazards Analysis l

l Operation of the FitzPatrick plant in accordance with the proposed Amendment would not involve a significant hazards consideration as stated in 10 CFR 50.92.

The following paragraphs describe, for each proposed change, why a significant hazards consideration is not involved.

Primary Containment Radioactivity Monitors The addition of these primary containment atmosphere sample lines:

1. Will not significantly increase the probability of an accident because the sample lines are a closed system outside containment. These lines are appropriately protected with isolation valves. The new lines are similar to the existing drywell atmosphere sample lines.

Therefore, there is no increase in tha probability that these lines will fail to isolate. The consequences of an accident are not increased because failure of all containment isolation valves associated with either the new or existing PCRMS sample line will not result in a direct path to the atmosphere. Containment leak rate may increase slightly due to the new penetrations but will remain within acceptable limits. No accidents are adversely affected because the lines are isolated in the event of an accident.

2. Will not create the possibility of a new or different kind of accident because the lines service an instrument; the PCRMS neither mitigatec nor can initiate an accident.

The purpose of the PCRMS is to provide information to plant operators during normal plant operation; PCRMS has no direct control function.

3. Will not involve a significant reduction in a margin of safety because the insignificant potential increase in containment leak rate is more than compensated for by the I' increase in PCRMS reliability. Potential radiological l

l l

Attachmont II consequences resulting from an un-isolatable break outside containment are enveloped by other more severe i accident analyses.

Service and Breathina Air Supolies to Drywell The cutting and capping of the service and breathing air supply lines:

1. Will not increase the probability of an accident Lecause passive components (welded caps) will replace active components (remotely-operated valves). The consequences of an accident will be decreased because the potential containment leakage will be slightly reduced. No accidents are adversely affected because the service and breathing air supplies to the drywell do not function to mitigate an accident. In-leakage from these air systems into the inerted containment will be eliminated.

2. Will not create the possibility of a new or different kind of accident because no new failure modes are introduced. The reliability of the containment to isolate in the event of an accident is increased.

3. Will involve a significant increase in a margin of safety because containment isolation dependability will be increased.

Residual Heat Remova] System Valve Chance The replacement of containment spray motor-operated gate valves with motor-operated globe valves:

1. Will not significantly increase the probability of an accident because operation of the containment spray system is not necessary to assure primary containment l integrity in the event of a LOCA. Globe valves are l not significantly different from gate valves in their l ability to isolate. No cccidents are adversely affected l because peak post-LOCA temperatures and pressures remain l below the maximums allowable. Drywell temperatures

and pressures remain within allowable limits for l environmental equipment qualification. Analysis have shown that chugging will not occur at containment spray flows of 1800 and 7000 gpm. The added ability to throttle containment spray flow will permit improved accident mitigation under certain circumstances.

2. Will not create the possibility of a new of different i kind of accident because the containment isolation function is not affected. No new failure modes are introduced as a result of this modification, Containment

, Attachment II spray functions to mitigate accidents, and cannot act as an accident initiator.

3. Will not involve a significant reduction in a margin of safety because the containment spray will still be able to perform its intended design function. The margin of safety will be increased because of the added ability to tilrottle containment spray flow rate.

Reactor Water Samole Valves The replacement of reactor water sample, containment isolation air-operated valves with solenoid-operated valves:

1. Will not significantly increase the probability of an accident because the containment isolation function of these valves is unchanged. Their ability to reliably isolate these sample line is not altered by the change in operator power source. Energy stored in a compressed spring is still used to close the valves.

2. Will not create the possibility of a new or different kind of accident because the containment isolation function is not affected. No new failure modes are introduced as a result of this modification. The valves automatically close on a loss of power.

3. Will not involve a significant reduction in a margin of safety because containment integrity is not reduced. The Reactor Water Sample System is unaffected in its ability to perform its intended function. The margin of safety will be increased because the operator will have positive indication of the position of these containment isolation valves.

V. IMPLEMENTATION OF THE PROPOSED CHANGE Implementation of the proposed changes will not impact the ALARA or Fire Protection Programs at FitzPatrick, nor will the changes impact the environment.

VI. CONCLUSION The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. These changes:

a. will not change the probability nor the consequences of an accident or malfunction of equipment important to

! safety as previously evaluated in the Safety Analysis Report;

, Attachmont II

b. will not increase the possibility of an accident or malfunction of a different type than any previously evaluated in the Safety Analysis Report;

c. will not reduce the margin of safety as defined in the basis for any technical specification;

d. do not constitute an unreviewed safety question; and

e. involves no significant hazards consideration, as defined in 10 CFR 50.92.

I

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, Attachment II l

VII. REFERENCES

1. NYPA letter, C. A. McNeill, Jr. to D. B. Vassallo, dated November 30, 1984 (JPN-84-077) regarding Regulatory Guide 1.97 implementation report for the James A. FitzPatrick Nuclear Power Plant.

2. NUREG-0737, "Clarification of TMI Action Plan Requirements,"

published November 1980. Item II.E.4.2, "Containment Isolation Dependability."

3. PASNY letter, J. P. Bayne to T. A. Ippolito, (JPN-82-005) dated January 7, 1982 regarding containment isolation dependability, NUREG-0737, Item II.E.4.2. Transmits containment isolation dependability study.

4. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report (FSAR) Sections 5.2, 7.3, and 14.6.

5. General Electric Co., Report AE-89-0984, DRF T23-443-1, October 1984, "James A. FitzPatrick Nuclear Power Plant Small and Intermediate Break LOCA Drywell Temperature Analysis and Drywell Spray Study."

6. General Electric Co., Report EAS-13-0388, DRF A00-03269, March 1988, "James A. FitzPatrick Nuclear Power Plant Containment Spray Flow Rate Analysis."

7. Updated Final Safety Analysis Report, James A. FitzPatrick Nuclear Power Plant, Figure 6.4-3, Rev. O, July 1982, "Process Diagram - Residual Heat Removal System."

8. General Electric Co., Report NSEO-51-0682, June 1982, "James A. FitzPatrick Nuclear Power Plant Drywell Temperature l

Analysis."

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