View source for JPN-91-014, Forwards Response to NRC 900918 Request for Addl Info Re 900530 Application for Amend to License DPR-59,changing Tech Specs to Reflect Installation of New Reg Guide 1.97 post-accident Monitoring Instruments

{{Adams
| number = ML20073A629
| issue date = 04/18/1991
| title = Forwards Response to NRC 900918 Request for Addl Info Re 900530 Application for Amend to License DPR-59,changing Tech Specs to Reflect Installation of New Reg Guide 1.97 post-accident Monitoring Instruments
| author name = Beedle R
| author affiliation = POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000333
| license number = 
| contact person = 
| case reference number = RTR-REGGD-01.097, RTR-REGGD-1.097
| document report number = JPN-91-014, JPN-91-14, NUDOCS 9104230286
| package number = ML20073A631
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 9
| project = 
| stage = Request
}}

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       #> NewYorkPower 4# Authority April 18,1991 JPN 91014 U.S. Nuclear Regulatory Commission Mail Station P1 137 Washington, D.C. 20555 ATTENTION:               Document Control Desk

==SUBJECT:==
James A. FitzPatrick Nuclear Power Plant Dockot No. 50-333 Request for Additional Infcrmation -
Accident Monitoring instrumentation Amendment (JPTS-89-015)

==REFERENCES:==
: 1.                          NYPA letter, J. C. Brons to the NRC, dated May 30,1990 (JPN.
90-042), " Proposed Chango to the Technical Specifications Regarding Accident Monitoring Instrumentation (JPTS-89 015)."
: 2.             NRC letter, D. E. LaBargo to J. C. Brons, dated September 18, 1990,"Roquest for AdditionalInformation Accident Monitoring         i instrumentation Amondment."

==Dear Sir:==

The Now York Power Authority applied for an amendment to the accident monitoring instrumentation requirements containod in the FitzPatrick Technical Specifications in Reforence 1. The chango proposed to updato the Technical                                   '
Specifications to reflect the installation of now Regulatory Guide 1.97 post accident monitoring instruments. During the NRC staff's review of this amendment application, they identified additional Information nooded to complete the review. Tho staff requested in Reference 2 that the Authority provido this information.
Attachment I to this letter contains the Authority's response to this request for information. Also includod in Attachment I is a description of soveral revisions to the amendment application. Attachment ll contains sovon revised Technical Specification pages which reflect those changes and resolves the NRC's concerns identified in Reference 2. Thoso pagos should be substituted into the set of revised Technical Specification pagos contained in Attachmont I to Reference 1.
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If you have any questions, please contact Mr. J. A. Gray, Jr.
Very truly yours, n: **                          .f
                                                                                                            ,                bC Ralph E. Boodle Exocutive Vice President Nuclear Gonoration STATE OF NEW YORK COUNTY OF WESTCHESTER Subscribed apd sworn to                  fore m this // % day of                                                                  1991.
un="Ed[0',. E,. . .
S7k Mb Notary'Public
                                                                                                 =c   29.!I.',,.,,,,
att:        as stated cc:       Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Mr. David E. LaBargo Project Directorate 11 Division of Roactor Projects 1/11 U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, D.C. 20555

ATTACHMENT I TO JPN 91-014 REQUEST FOR ADDITIONALINFORMATION ACCIDENT MONITORING INSTRUMENTATION AMENDMENT (JPTS-89-015)
New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333

Attachment 1 REQUEST FOR ADDITIONALINFORMATION page 1 of 6 ACCIDENT MONITORING INSTRUMENTATION (JPTS 89 015)
This attachment responds to the NRC's roquest for additional Information (Reforonce 2) concerning the Authority's application for an amendment to the FitzPatrick Technical Spocifications (Reference 1). The proposed amendment revises the instrumentation requilomonts associated with accident monitoring. The individual NRC questions are repeated followed by the Authority's reply. Following this discussion is notification of minor changes to the Authority's application.

===Background===
The original FitzPatrick plant design includod instrumentation to provido control room indication. Those insiniments do not have safety related control or trip functions. Technical Specification (TS) requiroments were appliod to a selected group of those instrumonts listed in Tablo 3.2 6 based upon the operator's nood to nave a rollable sourco of information concerning plant status. The TS Basos do not gato the basis for the selection of the specific plant paramotors. Howevor, this tarMs s!miiar to the TS of nuclear power plants sim!!ar in design to the FitzPatrick plant, and reflects good engincoring practico.
Since the Throo Milo Island event, the NRC and industry have made a significant effor' to identify the relativo importance of plant paramotor information nooded by operators during accidents. This resulted in the various categories of plant paramotors published in the NRC's Regulatory Guide (RG) 1.97. Category A is assigned to the plant paramotors that "... provido primary information noodod to permit the control room operating personnel to take the specified manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions..." Modifications to the FitzPatrick plant upgraded the instrumentation which monitors these Category A parameters.
The Authority then proposed Technical Specification requirements for the Category A accident monitoring instrumentation in Table 3.2-8 to replace Table 3.2 6.
The proposed Table 3.2-8 is very similar to the existing Table 3.2 6. Both tables place operational requiremonta on instruments which provido control room indication, and most of the plant paramotors listed in the two tables are identical. However the purpose of the now table is different. Table 3.2 6 provided TS requirements for instruments used in the day to-day oporation of the FitzPatrick plant, whereas the proposed Table 3.2-8 providos TS requirements for the instrumentation to be used under accident conditions. One exception concerns the Containment High Rango Radiation Monitor. This instrument has an isolation function as well as control room indication. The paramotors selected and the design of the instrumentation in the proposed tablo are a result of a documented and approved methodology, not engineering judgement. The Authority's intent in the proposed amendment is to replace the existing judgement based Table 3.2 6 with the now RG 1.97 based Table 3.2 8.
As noted above, many of the RG 1.97 Category A piant parameters were already listed on Table 3.2 6. However, the proposed Table 3.2 8 actually reflects many new or upgraded instruments, not the ones covered by the existing Table 3.2-6. The LCO's, action statomonts, and surveillanco requirements in the proposed Table 3.2 8 reflect the design of the new instrumentation system and current standards reflected in RG 1.97 and the STS. The now specifications apply to mostly now instruments, not revised requirements for old instruments.

Attachment 1 REQUEST FOR ADDITIONALINFORMATION j                                                                                  pago 2 of 6 Tho Authority boliovos that the relationship betwoon the two tables is the prirrnry source of the NRC's questions. Thorofore, the responses to many of the individual questions will referonce information provided above.
Response to Individual Requests for int'ormation NRC Ouestion
: 1.      The proposed submittal would add the requiremont to Spocification 3.2.H that tho instrumentation in Table 3.2 8 'must bo operable whenever the reactor is critical and reactor coolant temperature is greator than or equal to 212 F.* Please address the following concerns related to this proposed chango:
: a. For all of the instruments in Table 3.2-8, the proposed chango to Specification 3.2.H sooms to imply that both conditions of coolant temperature and reactor criticality must be in offect before the instrumentation is required to be operable.
However, this is inconsistent with the requirements of primary containment intogrity Specification 3.7.A.2, which statos that the existence of either condition requires that rimary containment intogrity be in offect. Sinco many of the instruments are associated with monitoring of the primary containment, Specification 3.7.A.2 would scom to form the basis for the operability requirements for the instruments associated with the primary containment in tho
   =
proposed change.
NYPA Responso The existing TS 3.2.F,3.2.H, and Tables 3.2.6, "Surveillanco Instrumontation' and 3.2.8,
                                    " Accident Monitoring Instrumentation
* do not specify the plant conditions under which the instruments are required to be operable. In practico, those indruments have boon considered part of the monitored system and were to be oporable whenover the monitored system was operable. The Authority proposed to reviso TS 3.2.H to provide uniform operability requirements for all accident monitoring instrumentation. This change would be an additional constraint added to the TS.
Technical Specification 1.0.J defines operable to include "... all nocessary attendant instrumentation ... that se required for the system to perform its function (s) are also capable of performing their related support fur ctions(s)." From this definition, only thoso Instrumonts necessary for the primary containment to perform its function are required to be operable whenover primary containment integrity is requirod. Table 3.21, " Instrumentation that Initiates Primary Containment Isolation," contains those Instruments which are required for the containment isolation system to perform its function in addition, containment intogrity requirements also includo items such as closure of hatches, blind flanges, etc., which have no associated instrumentation.
The proposed Table 3.2 8 Instrumentation provides indication only, and even when inoperable, does not provent the containment isolation system from performing its function nor affects containment Integrity. The Instrumentation on Table 3.2 8 Is intended to provide accident monitoring information, not system operability. Thorofore, TS 3.7.A.2 does not provide the basis for the operability requirements for the Table 3.2 8 accident monitoring instrumentation.
4

Attachment i                                                                  !
REQUEST FOR ADDITIONALINFORMATION pago 3 of 6 To clarify the distinction betwoon the operability requirements for primary containment isolation instrumentation and accident monitoring instrumentation, the Authority is relocating the accident monitoring instrumentation operability requirement from Specification 3.2.H to Table 3.2-8. A now column, titled ' Mode in Which Instrumentation Must be Operablo" is added to the table, in this column will be a reference to either Note H or J for each instrument. These notes specify that all accident monitoring instrumentation must bo operable whenever the reactor is in the Startup/ Hot Standby or Run mode, in addition, the Containment High Rango Radiation Monitor, Turbino Building, Radwasto Building, and Stack High Range Effluent Monitors must also be operable in the Hot Shutdown modo.
These conditions are more rostrictive than those originally proposed by the Authority and those suggested in the NRC's Roquest for Additional Information. These conditions more closely paralloi the "Applicabie Operational Co .ditions" of STS Table 3.3.7.51 and the TS of other BWRs. Revised pagos 54,77a,77b,77c, and 77d are included in Attachment II.
NRC Question 1.b.
The proposed chango does not include the primary containment integrity requirement of Specification 3.7.A.2 concerning fuel in the reactor vessel.
NYPA Responso Instrumentation necessary to initlato containment isolation are contained in TS Table 3.21.
Note 1 to this tablo requires this instrumentation to be operable whenover the primary containment is required according to Section 3.7. See the Authority's response to 1.a above.
1 NRC Ouestion 1.c.
The proposed change to Table 3.2-8 would add certain Residual Heat Removal (RHR) systom, RHR Service Water, and Core Spray (CS) system Instruments.
Howevor, the proposed changes to Specificatior' 3.2.H and to Table 3.2 8 do not recognize the operability requirements of the RHR and the CS systems of Specification 3.5.A or the definition of "Oporable". stated in Specification 1.0.J.
NYPA Responso Operability requirements for the Core Spray and Residual Heat Removal systems are contained in TS 3.5.A.1 and 3.5.A.3 respectively. The instrumentation required for these systems to be operable as defined in TS 1.0.J are contained in TS Table 3.2 2,
            " Instrumentation that Initiates or Controls the Core and Containment Cooling Systems.'
The proposed Table 3.2-8 providos post accident monitoring instrumentation requirements, not ECCS system operability requirements. As defined in RG 1.97, the purpose of accident monitoring instruments Is to ' provide primary Information nooded to permit the control room operating personnel to take the specified manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for design basis accident events." The accident monitoring instrumentation provides indication only, and even when inoperable, does not prevent the monitored ECCS system from performing its function. These post accident qualified instruments are not a prerequisite for system operability. Therefore, these instruments do not have to be operable whenever the monitored ECCS system is operable.

Attachment i REQUEST FOR ADDITIONALINFORMATION page 4 of 6 NRC Ouestion                                                                                                         .
: 2. The present TS Table 3.2-6 Indicates that the number of reactor pressure channels provided by design is three and that the minimum number of oporable instrument channels is two. The proposal would move this parameter to Table 3.2-8 and would indicato that only two channels aro provided by design and that the minimum number required would be one. This change to the number of channels is not discussed in the                               .-
submittal.
                                                                                                                                =
NYPA Responso The NRC provided guidancs in RG 1.97, position C.1.3.1.b and in STS Table 3.3.7.51 for the number of reactor pressure accident monitoring instrument channels. Two reactor pressuro                                  '_
instrument channels are specified by both of those documents. Thorofore, the Authority             '
instalU two now post accident qualified reactor pressure Instruments as reflected in the                                   <- - -
proposed TS. The thr00 reactor pressure instruments contained in Table 3.2-6 are not post-                                      '
accident qualified and are not included in Table 3.2-8.                                                          -
The proposed TS places operability requiremonts on the RG 1.97 post accident qualified instrumentation regardless of the number of non-qualified instruments already installed.
Thoroforo, there can be differences betwoon the two tables with respect to the number of installod instruments for any given plant paramotor. Reduction in the number of reactor                                      .
pressure instrument channels specified by the TS does not reduce the level of safety afforded by the FitzPatrick plant. Instead, plant safety is enhanced because TS are being appiled to instruments qualified for post accident conditions.
NRC Ouestion
: 3.      There appears to be no justification supplied for the significant differences between the Action Statement in the prosent TS and that shown in the submittal, for the following paramotors:                                                                                               .
: a. Torus Water Lovel
: b. Reactor Water Lovel (wide range)
: c.      Reactor Water Lovel (fuel zono)
: d. Reactor Vossel Pressure
: e. Torus Water Temperaturo
: f.      Drywell Temperature
: g.      Drywell/ Torus Differontial Pressuro Please ensure that for every change that is proposed in the submittal, a corresponding                .
explanation is provided.
NYPA Response As stated in Section lli of the application safety evaluation, "The ... action statements in revised Table 3.2 8 were selected based upon the redundancy in the design of the instrumentation system. This is consistent with the operability requirements for other post-accident instrumentation at the FitzPatrick plant." Although these action statomonts may be            .
b

Attachment l REQUEST FOR ADDITIONALINFORMATION page 5 of 6 difforont from those in the existing Table 3.2-6, they are also appliod to differont instruments and serve a different purposo.
The bases for the proposed action statomonts include:                                                   E
           . A prior, similar TS chango (Amondment 130);
           . Other TS action statomonts for ltoms of similar safety significance;
           . The rodundancy and expected rollability of the accident monitoring instrumentation           E design;                                                                                      E
           . The normal operational status of the instrument and the monitored paramotor;                      M
           . The availability of many non post accident qualified instruments which monitor the                g same plant paramoters;                                                                           = --
           . Those instruments do not provide any control functions; and
            . Guidance from STS Table 3.3.7.51 and other BWR plants TS.                                           !
These bases apply to all plant paramoto's monitored in the proposed Table 3.2-8. Note also                         5-that the action statomonts apply only to indicators, not to the monitored plant paramotors.
Therefore, the proposed action statomonts are reasonable and appropriato.                                            =
F NRC Ouestion                                                                                                         U
: 4. The present TS Table 3.2-6 contains the Supprossion Chamber Water Level (Wido                      __
Range) instrument. However, the wide range instrument is not indicated in tho                                    <
proposed TS change and thoro is no explana lon for its dolotion,                                                  g NYPA Response                                                                                                            ;
Supprossion Chamber Water Level (Wide Range) is included in the proposed Table 3.2-8 as                                   ;
Item 8. It is labeled ' Torus Water Level." It is the wide range instrument sinco it has a span of 25.7 feet. The Authority will identify this instrument bottor in Tables 3.2-8 and 4.2-8 by                  _
renaming it " Torus Water Level (wide range)." Revised pages 77b and 86 are onclosed in                                -
Attachment II.
NRC Ouestion                                                                                                         _
: 5. To be consistent with other applications of the term, a */* should be placed betwoon
          " Safety
* and " Relief
* shown on TS page 77d in the submittal.
NYPA Responso The Authority agrees with the NRC staff and is enclosing a revised pago 77d in Attachment 11.
NRC Ouestion                                                                                                   __
: 6. The submittal describes deletion of Tablo 4.2-6 from the TS, which is on pago 84 of the present TS and moves the
* NOTES FOR TABLES 4.21 THROUGH 4.2 5* onto pago 84.                        --
The result is that there is no page to show that Table 4.2-6 is intentionally blank, as was     -
done on the now page 76 for deletion of Table 3.2-6. Thus, the numbering sequence of the tables would go from 4.2 5 to 4.2 7.

Attachment i REQUEST FOR ADDITIONALINFORMATION pago 6 of 6 NYPA Responso The Authority proposed to amond tho "Ust of Tables' to show that both Tables 3.2-6 and 4.2-6 are doloted and there is no corresponding pago for the now nonexistent Table 4.2 6. The Authority's practico of amending a page with "This Page is Intentionally Blank' when the entire contents of that page Is doloted is only to maintain page numbering consistency within the TS. Such was the case for the deletion of Table 3.2-6. Otherwise the page is removed or roused, and no reference is made to what had formerly boon on that page. In the caso of the doloted Table 4.2 6, there is no nood to retain a blank page for page numbering consistency.
Since no TS will refer the reader to the doloted table, thoro is no nood to identify its formor location within the TS. The Authority acknowleges that the sequence of tables within the TS will go from 4.2 5 to 4.2 7.
Additional Changes The Authority is proposing the following minor Technical Specification changes in addition to those discussed above. After the originai amendment application was submittod, the Authority identified a typographical error in one instrument ID number. Item 20 of Table 3.2 8 should refer to instrument 23Ll 201 A rather that 27Ll 201 A. Item 9 of Tables 3.2 8 and 4.2-8 is being revised from " Torus Water Temperaturo' to Torus Bulk Water Temperature" to more accurately describe this instrument's function. The entries in the Table 3.2-8 ' Action" column aro being prefaced with the word " Note." In addition, the Table 4.2-8 column heading
   " Check' is being renamed " Instrument Check" to be consistent with the existing Table 4.2 8.
The revised pages in Attachment 11 reflect these changes.
References
: 1. NYPA letter, J. C. Brons to the NRC, dated May 30,1990 (JPN 90-042), " Proposed chango to the Technical Specifications Regarding Accident Monitoring Instrumentation (JPTS-89-015)."
: 2. NRC letter, D. E. LaBargo to J. C. Brons, dated September 18,1990, "Roquest for AdditionalInformation Accident Monitoring instrumentation Amendment."}}