ML20154Q925

Forwards RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions

ML20154Q925
Person / Time
Site:	FitzPatrick
Issue date:	10/19/1998
From:	Williams J NRC (Affiliation Not Assigned)
To:	James Knubel POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
GL-96-06, GL-96-6, TAC-M96812, NUDOCS 9810260106
Download: ML20154Q925 (5)

Text

-.- . .. ~. . . . - - -

• - Mr. J mes Knubel i

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Chl;f Nucinr Officer Power Auth::rity of th) Stata cf New York 123 Main Street l White Plains, NY 10601

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT- DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-06 (TAC NO. M96812) l

Dear Mr. Knubel:

On July 30,1998, you provided additionalinformation regarding your response to Generic Letter 96-06, " Assurance of Equipment Operability and Containment integrity During Design l Basis Accident Conditions." The NRC staff has determined that additionalinformation regarding your response will be required to complete its review of this issue. A draft copy of the information request was provided to you on September 29,1998. The final request for additional information is given in the enclosure, and is unchanged from the September 29 draft. On October 5,1998, Mr. Art Zaremba of your staff informed me of your intent to provide the requested information within 30 days of the end of the upcoming FitzPatrick refueling outage. If you have questions on this topic, please contact me at (301) 415-1470.

Sincerely, original signed by:

Joseph F. Williams, Project Manager

, Project Directorate 1-1 Division of Reactor Projects - l/II Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Request for Additional Information cc w/ encl: See next page DISTRIBUTION:

Docket File S. Little DfoI l l PUBLIC J. Williams PDl-1 R/F OGC J. Zwolinski ACRS t C}'((.k()[8$CE2-m Q2VUpy d

S. Bajwa C. Hehl, Region l a$yng2 El UN G. Hammer DOCUMENT NAME: G:\FITZ\M968128.RAI To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with

. cttachment/ enclosure "N" = No copy ,

OFFICE PM:PDI-1 /[4 l E LA:PDI-1J)L l D:PCI 1 , A l l l NAME JWilliams/rst W4/ SLittleC SBajwa /F%

DATE 10/t9 /98 # 10/)q/98 10/l4 /98

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, .,; ; Official Record Copy 9810260106 981019 PDR ADOCK 05000333 P PDR

A MGU A g +2 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001

'+[.....,o October 19, 1998 Mr. James Knubel Chief Nuclear Officer Power Authority of the State of New York 123 Main Street White Plains, NY 10601

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT- REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-06 (TAC NO. M96812)

Dear Mr. Knubel:

On July 30,1998, you provided additional information regarding your response to Generic Letter 96-06,' " Assurance of Equipment Operability and Containment integrity During Design Basis Accident Conditions." The NRC staff has determined that additionalinformation regarding your response will be required to complete its review of this issue. A draft copy of the information request was provided to you on September 29,1998. The final request for additional information is given in the enclosure, and is unchanged from the September 29 draft. On October 5,1998, Mr. Art Zaremba of your staffinformed me of yourintent to provide the requested information within 30 days of the end of the upcoming FitzPatrick refueling outage. If you have questions on this topic, please contact me at (301) 415-1470.

Sincerely,

/A

'/ Joseph F. Wiliams, Project Manager-Project Directorate 1-1 Division of Reactor Projects - 1/ll Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Request for Additional Information cc w/enci: See next page

p. s jr .

7 M James Knubel James A. FitzPatrick Nuclear l Power Authority of the State - Power Plant

' i of New York -

4 cc: .

i.

. Mr. Gerald C. Goldstein Mr. F. William Valentino, President Assistant General Counsel New York State Energy, Research,

) Power Authority of the State and Development Authority ,

i of New York Corporate Plaza West '

, 1633 Broadway 286 Washington Avenue Extension

! . New York, NY 10019 Albany, NY 12203-6399 Resident inspector's Omce Mr. Richard L. Patch, Director

- U. S. Nuclear Regulatory Commission Quality Assurance P.O. Box 136 Power Authority of the State Lycoming, NY 13093 of New York 123 Main Street Mr. Harry P. Salmon, Jr. White Plains, NY 10601

.Vice President - Engineering Power Authority of the Sta's Mr. Gerard Goering of New York 28112 Bayview Drive 123 Main Street Red Wing, MN 55066 White Plains, NY 10601 Mr. James Gagliardo Ms. Charlene D. Faison Safety Review Committee Director Nuclear Licensing 708 Castlewood Avenue Power Authority of the State Arlington, TX 76012 of New York 123 Main Street Mr. Arthur Zaremba, Licensing Manager White Plains, NY 10601 James A. FitzPatrick Nuclear Power Plant Supervisor P.O. Box 41 Town of Scriba Lycoming, NY 13093 Route 8, Box 382 Oswego,NY 13126 Mr. Paul Eddy New York State Dept. of Mr. Eugene W. Zeltmann Public Service

- President and Chief Operating 3 Empire State Plaza,10th Floor Officer . Albany, NY 12223 Power Authority of the State of New York Michael J. Colomb 99 Washington Ave., Suite No. 2005 Site Executive Officer Albany, NY 12210-2820 James A. FitzPatrick Nuclear Power Plant P.O. Box 41 Charles Donaldson, Esquire Lycoming, NY 13093 Assistant Attomey General New York Department of Law 120 Broadway New York, NY 10271

. Regional Administrator, Region i

.U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

F ,

A JAMES A. FITZPATRICK NUCLEAR POWER PLANT 4 GENERIC LETTER 96 ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN BASIS ACCIDENT CONDITIONS REQUEST FOR ADDITIONAL INFORMATION

1. In its July 30,1998, submittal, the New York Power Authority (NYPA, also known as the Power Authority of the State of New York) indicated that a total of 23 pipe segment penetrations were potentially susceptible to thermally-induced pressurization. NYPA stated 4

that 9 of these segments are Reactor Building Closed Loop Cooling (RBCLC) containment penetrations for which there would be no thermal pressurization damage due to the following two considerations. The first consideration is that fluid pressure would lift the air operated globe valves by pressurizing under the valve seats. The second consideration is that the isolation valves require manual isolation which does not occur until after 10 minutes following a loss-of-coolant accident which would preclude enough heatup within the penetrations to cause thermal pressurization.

Please provide the following information for these penetrations:

A. Describe the applicable design criteria for the piping and valves. Include the required load combinations; B. Provide a drawing of the valve. Describe the method used to estimate the pressure at which the valve was determined to lift off its seat or leak. Discuss any sources of uncertainty associated with the estimated valve disk lift off or leakage pressure; C. Provide the maximum-calculated stress in the piping run based on the estimated lift off orleakage pressure; D. The licensee states that plant operating procedures only direct the operators to isolate the valves for these penetrations if there are symptoms of a breach in the RBCLC piping

' and that 10 minutes elapsed time is assumed for operator action. Describe how the plant operating procedures assure that the operators would not take action at any time prior to 10 minutes; E. Provide the maximum-calculated temperature and pressure for the pipe runs. Describe, in detail, the method used to calculate these pressure and temperature values. This description should include a discussion of the heat transfer model used in the analysis and the basis for the heat transfer coefficients used in the analysis, include the lengths and thicknesses of the piping segments and the type and thickness of the insulation.

2. In its July 30,1998, submittal, NYPA stated that 11 of the 23 pipe segment penetrations were evaluated for the thermal pressure conditions which would occur with the consideration that an isolation valve would lift off its seat to limit the pressure. For these, the licensee evaluated the pipe stresses due to thermal pressurization and other loads in accordance with ASME Appendix F criteria.

Enc 1osure

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l Please provide the following information for these penetrai;ons: I A. The acceptance criteria includes a load combination for a Normal / Upset Primary Stress condition which is 2.4 times the basic allowable stress at temperature. Since Appendix  :

, F does not address Normal / Upset conditions, the staff believes that the 2.4 factor is '

l inappropriate for these conditions. Please provide clarification regarding the appropriate criteria for Normal / Upset thermal pressurization conditions and how it is applied to the components evaluated; I B. The licensee does not combine thermal pressurization loads with occasional hydrodynamic loads. The licensee states that hydrodynamic loads will dissipate before intemal pressure can significantly increase. Describe in detail the hydrodynamic loads l

which can occur for these penetrations and when they specifically occur relative to thermal pressurization for licensing basis events; C. Describe the applicable design criteria for the isolation valves. Include the required load combinations; D. Provide a drawing of the valves. Describe the method used to estimate the pressure at which the valve was determined to lift offits seat or leak. Discuss any sources of uncertainty associated with the estimated valve disk lift off or leakage pressure; l

l E. In addition, for two of these 11 penetrations (X-18 and X-19), NYPA states that the leak path generated through one of the isolation valves is "non-resealing" due to the seat i materials. This infers that the leak would be caused due to significant deformation of the valve intemais. This scenario appears to involve much more uncertainty in determining the peak pressure than for a valve where fluid pressure under a disk acts against a linear-elastic spring resistance. The licensee also relies on the other isolation valve remaining leak-tight until this valve leaks to relieve the fluid pressure. Address the uncertainty in determining the peak pressure and how it is assured that the sole remaining containment isolation valve wil; remain leak-tight and not undergo similar j damage during the pressurization.

3. In its submittal dated July 30,1998, NYPA stated that Pipe Line Numbers 3"-WL-151-1 A and 18 may also be subject to thermal pressurization, but were not analyzed since they are not required for containment integrity. Please verify that containment isolation is the only safety function of this system.

l

4. In its submittal dated July 30,1998, the licensee also stated that for High Pressure Coolant injection penetration X-226, isolation valve leakage tests would be required, "perhaps on a periodic basis," to verify sufficient leakage to prevent pressure Iccking of the valves. Please clarify the specific frequency of the tests necessary to verify the required leakage.

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