ML20235Y721
| ML20235Y721 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/13/1987 |
| From: | POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20235Y625 | List: |
| References | |
| NUDOCS 8710200461 | |
| Download: ML20235Y721 (9) | |
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l ATTACHMENT I TO JPN-87-052 PROPOSED TECHNICAL SPECIFICATION CHANGES t
REGARDING SCRAM DISCHARGE SYSTEM OPERABILITY (JPTS-87-004) 3 I
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1 New York Power Authority JAMES A.
FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 I
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i ATTACHMENT II TO JPN-87-052 SAFETY EVALUATION ' FOR PROPOSED TECHNLCAL SPECIFICATION CHANGES REGARDING SCRAM DISCHARGE SYSTEM OPERABILITY (JPTS-87-004) l 1
4 New York Power Authority JAMES A.
FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59
L I.
DESCRIPTION OF THE PROPOSED CHANGES l-l 4
The changes to the James A.
FitzPatrick Technical Specifications is limited to four changes on pages 89a and 90.
These changes are:
1.
Specification 4.3.A.2.e is relocated to the right column.
2.
In the second sentence of specification 4.3.A.2.e, the colon is replaced with a comma and the word "a" is added.
The blank line following the colon is deleted.
i 3.
The period is removed from the end of paragraph 3.3.A.2.d. This specification, which continued on page 90, is relocated in its entirety to.page 89a.
4.
Specification 4.3.A.2.g is deleted in its entirety.
Items 1 through 3 are administrative in nature and involve the correction of typographical or grammatical errors.
The Specification to be deleted (item 4) currently reads as follows:
i "At least once per operating cycle, the operability of the entire scram discharge system as an integrated whole shall be demonstrated by a scram of control rods from a normal control rod configuration of less than or equal to 50% rod density by verifying that the drain and vent valves:
1.
Close upon receipt of a signal for control rods to scram; and i
2.
Open when the scram signal is reset.
This requirement may be satisfied as part of any scram originating from the rod density conditions specified above, provided that specification 4.3.A.2.f is independently satisfied during the quarter in which the scram occurs."
II.
EURPOSE OF THE PROPOSED CHANGES The purpose of the existing specification is to verify the operability of the scram discharge system.
A scram is performed from a specified rod density so that the scram discharge volumes receive water discharged from the control rod drives.
This water then drains by gravity into the two scram discharge instrument volumes.
The scram discharge instrument volume drain and vent valves are monitored to assure that they close when required by a scram signa) and subsequently reopen when the scram is reset.
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The scram discharge system modification was installed to assure the hydraulic coupling of the gravity drain from the scram discharge volume to the scram discharge instrument volume.
With the exception of the initial post-modification verification test, initiating full scrams is not necessary to assure the discharge volume to instrument volume hydraulic coupling.
The operability of the scram discharge volume drain and vent valves is assured by performance of other technical specification surveillance requirements which do not require a scram from power.
The Authority did not consider this surveillance test necessary to support the scram discharge system modification.
The test was therefore not included as part of the requested technical specification changes (Reference 3).
The surveillance test was subsequently requested by the NRC staff and agreed to by the Authority.
The Authority now proposes to delete this specification to eliminate an unnecessary challenge to the reactor protection system, and avoid subjecting the plant to an unnecessary thermal transient.
III. IMPACT OF THE PROPOSED CHANGES The scram discharge system at FitzPatrick was modified in accordance with Reference 3 to assure the hydraulic coupling of the scram discharge volume to the instrument volume.
Additional surveillance requirements, added as part of Amendment No. 75 to the Technical Specifications (Reference 5), were intended to assure the operability of the scram discharge system.
Among these surveillance is the specification the Authority now proposes to delete.
Technical Specifications 4.3.A.2.b, 4.3.A.2.f, 4.3.C.3, and the surveillance requirements of Table 4.1-1 and Table 4.1-2 adequately assure the operability of the scram discharge system.
Specification 4.3.A.2.b reads:
"The scram discharge volume drain and vent valves shall be verified open at least once per 31 days (these valves may be closed intermittently for testing under administrative control)."
Specification 4.3.A.2.f reads:
"The scram discharge volume drain and vent valves shall each be full-travel cycled at least once per quarter to verify that the valves close in less than 30 seconds and to assure proper valve stroke and operation."
h Specification 4.3.C.3 reads:
"All control rods shall be determined operable once each operating cycle by demonstrating the scram discharge volume drain and vent valves operable when the scram test initiated by placing the mode switch in the SHUTDOWN position is performed as required by Table 4.1-1 and by verifying that the drain and vent valves:
1.
Close in less than 30 seconds after receipt of a signal for control rods to scram, and 2.
Open when the scram signal is reset or the scram discharge instrument volume trip is bypassed."
The functional testing and calibration of instrumentation associated with the reactor protection is specified in Tables 4.1-1 and 4.1-2.
The specification to be deleted is functionally redundant to Specification 4.3.C.3 which initiates a scram test to verify the performance of the scram discharge drain and vent valves.
Since the hydraulic coupling of the scram discharge volume to the instrument volume is assured by design and has been verified by 15 scrams, a " surveillance" scram from 50% rod density is not necessary.
A survey of BWR plants has shown that 13 out of 17 polled-do not have a surveillance requirement to scram the reactor from a specified rod density to verify the scram discharge system performance.
Deletion of this specification will make the FitzPatrick Technical Specifications consistent with the applicable specifications at most BWR plants.
This change is also consistent with the requirements of recently issued standard technical specifications (e.g. Reference 6).
Deletion of specification 4.3.A.2.g is consistent with the philosophy of reducing the number of challenges to the reactor protection system and unnecessary thermal transients.
IV.
EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION 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 since it would not:
1.
involve a significant increase in the probability or l
consequences of an accident previously evaluated.
The removal of this surveillance requirement does not af fect any accident as ar.alyzed in the FSAR.
Other l
surveillance requirements exist in the Technical Specifications which assure the operability of the scram discharge system to perform as required during a reactor protection system actuation.
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2.
create the possibility of a new or different kind of accident.from any accident previously evaluated.
The-elimination of an unnecessary surveillance requirement and challenge to the reactor protection system cannot initiate or contribute to a new or different accident.
3.
involve a significant reduction in a margin of safety.
This surveillance requirement was intended to demonstrate operability of the scram discharge system' which is assumed in the'FSAR accident analyses.
Removal of this surveillance has no effect on these analyses since the design of the modified system together with other technical specification surveillance requirements assure the operability of the i
scram discharge system.
The resulting elimination of an unnecessary challenge to the reactor protection system is consistent with industry and regulatory philosophy and goals.
V.
IMPLEMENTATION OF THE PROPOSED CHANGE Implementation of these changes, as proposed, will not f
impact the ALARA or Fire Protection Programs at FitzPatrick, nor j
will the changes impact the environment.
i VI.
CONCLUSION The change, as proposed does not constitute an unreviewed safety question as defines in 10 CFR 50.59, that is it:
will not change the probability nor the consequences of a.
an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report; b.
Will not increase the possibility of an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report; will not reduce the margin of safety as defined in the c.
basis for any technical specification; d.
does not constitute an ur reviewed safety question; and involves no significant hazards consideration, as e.
defined in 10 CFR 50.92.
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~ VII.
REFERENCES 1.'
James A. FitzPatrick Nuclear Power Plant. Final Safety
.l Analysis Report (FSAR).
2.
James A. FitzPatrick Nuclear Power Plant Safety Evaluation 1
Report (SER).
i 3.-
NYPA letter,.J.
P.
Bayne to D.
B. Vassalo, JPN-83-63,' dated
' July 7, 1983.
. 4.-
NRC Generic Safety Evaluation Report titled, "BWR Scram Discharge System," dated December 1, 1980.
1 5.
NRC letter,' J.
D. Hegner to J.
P.
Bayne, transmitting' Amendment 75 of the FitzPatrick Technical Specifications, dated August 26, 1983..
6.
. Hope Creek Technical' Specifications, Surveillance Requirements 4.1.3.1.1 and 4.1.3.1.4 on pages 3/4 1-4,5.;
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