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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M1851999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Requal Pass Dates JPN-99-035, Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 11999-10-15015 October 1999 Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 1 JPN-99-034, Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping1999-10-13013 October 1999 Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping JPN-99-033, Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon1999-10-0808 October 1999 Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon JPN-99-030, Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days1999-09-29029 September 1999 Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days JPN-99-032, Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request1999-09-29029 September 1999 Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request ML20212F8341999-09-22022 September 1999 Forwards Insp Rept 50-333/99-07 on 990718-0828.No Violations Noted JAFP-99-0262, Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl1999-09-16016 September 1999 Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl ML20212A8341999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics ML20212A6951999-09-0909 September 1999 Requests That Licensees Affected by Kaowool Fire Barriers Take Issue on Voluntary Initiative & Propose Approach for Resolving Subj Issues.Staff Plans to Meet with Licensees to Discuss Listed Topics 05000333/LER-1998-015, Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete1999-09-0808 September 1999 Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete ML20211N4301999-09-0808 September 1999 Discusses Proposed Meeting to Discuss Kaowool Fire Barriers. Staff Requesting That Affected Licensees Take Issue on Voluntary Initative & Propose Approach for Resolving Issues JAFP-99-0258, Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld1999-09-0808 September 1999 Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld JPN-99-028, Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity1999-08-30030 August 1999 Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity JAFP-99-0247, Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 41999-08-26026 August 1999 Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 4 JAFP-99-0245, Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 19991999-08-19019 August 1999 Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 1999 ML20210U2621999-08-12012 August 1999 Forwards Insp Rept 50-333/99-06 on 990601-0717.No Violations Noted JPN-99-025, Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams1999-08-0505 August 1999 Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams JPN-99-026, Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds1999-08-0505 August 1999 Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds ML20216D9421999-07-28028 July 1999 Forwards Safety Evaluation Granting Requests for Relief from Requirements of ASME Code,Section XI for Second 10-year ISI Interval for James a FitzPatrick NPP JAFP-99-0229, Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1)1999-07-22022 July 1999 Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1) JAFP-99-0228, Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal1999-07-21021 July 1999 Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal ML20210A7001999-07-16016 July 1999 Forwards Request for Addl Info to Supplement Response Provided for GL 97-05, Steam Generator Tube Insp Techniques JAFP-99-0208, Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl1999-07-14014 July 1999 Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl ML20209D5511999-07-0606 July 1999 Informs That as Result of NRC Review of Licensee Response to GL 92-01,rev 1,suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2 ML20210C9031999-06-30030 June 1999 Summarizes Impact of Changes & Errors in Methodology Used by GE to Demonstrate Compliance with ECCS Requirements of 10CFR50.46.Summary of Changes & Errors Provided in Attached Table JPN-99-021, Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend1999-06-22022 June 1999 Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend JPN-99-020, Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept1999-06-21021 June 1999 Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept ML20196G2981999-06-18018 June 1999 Forwards Insp Rept 50-333/99-04 on 990412 to 0529.Violations Being Treated as non-cited Violations ML20212J0541999-06-17017 June 1999 Responds to Requesting That NRC Staff ...Allow BWR Plants Identified to Defer Weld Overlay Exams Until March 2001 or Until Completion of NRC Staff Review & Approval of Proposed Generic Rept,Whichever Comes First JPN-99-019, Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant1999-06-15015 June 1999 Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant ML20196L1451999-06-0707 June 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Ss Bajwa Will Be Section Chief for Ja Fitzpatrick & Indian Point NPPs JPN-99-018, Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1)1999-06-0101 June 1999 Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1) ML20207D9191999-05-27027 May 1999 Informs That on 990521 NRC Staff Held Planning Meeting to Identify Insp Activities at Facility Over Next Six Months JAFP-99-0171, Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr1999-05-20020 May 1999 Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr JPN-99-016, Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl1999-05-19019 May 1999 Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl ML20207A6751999-05-17017 May 1999 Forwards RAI Re 960626 Submittal & Suppl Related to IPEEEs for Plant.Licensee Committed to Revise Plant Fire IPEEE to Reflect Issues Associated with EPRI Fire PRA Implementation Guide within 120 Days of Issues Resolution JAFP-99-0168, Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls1999-05-13013 May 1999 Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls ML20206N0721999-05-11011 May 1999 Forwards Insp Rept 50-333/99-03 on 990301-0411.Four Violations of NRC Requirements Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy JAFP-99-0160, Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 41999-04-30030 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 4 ML20206C8551999-04-27027 April 1999 Informs That Util 990406 Submittal, Licensing Rept for Reracking of Ja FitzPatrick Spent Fuel Pool,Rev 7, Will Be Marked as Proprietary & Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) ML20205T1141999-04-22022 April 1999 Provides Comments from Technical Review of Draft Info Notice Re Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station,Unit 2,ANO,Unit 2 & JAFNPP JPN-99-012, Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached1999-04-16016 April 1999 Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached ML20205P4641999-04-15015 April 1999 Forwards for Review & Comment Draft Info Notice That Describes Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station Unit 2,Arkansas Nuclear One Unit 2 & Ja Fitzpatrick NPP ML20205P1991999-04-0909 April 1999 Discusses 990224 PPR & Forwards Plant Issues Matrix & Insp Plan.Advises of Planned Insp Effort Resulting from Plant PPR Review JAFP-99-0129, Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick1999-04-0909 April 1999 Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick JAFP-99-0127, Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld1999-04-0808 April 1999 Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld JAFP-99-0124, Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) ML20205M8941999-04-0707 April 1999 Forwards Rev 21 to App C of JAFNPP Emergency Plan & Rev 1 to EAP-32, Recovery Support Group Manager JAFP-99-0125, Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARJPN-99-035, Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 11999-10-15015 October 1999 Forwards Comments on Version 2 of Reactor Vessel Integrity Database for Plant.Table Listing Recommended Changes to Info in Rvid,Encl as Attachment 1 JPN-99-034, Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping1999-10-13013 October 1999 Forwards Proposed risk-informed ISI Program,Provided from NRC Review & Approval as Alternative to Current ASME Section XI Insp Requirements for Class 1 & 2 Piping JPN-99-033, Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon1999-10-0808 October 1999 Provides Response to Questions Contained in 990712,facsimile from NRC Re Ja FitzPatrick USI A-46 Program.Questions Were Also Discussed Between Members of Util & NRC Staff During Telcon JPN-99-030, Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days1999-09-29029 September 1999 Forwards Application for Amend to License DPR-59,proposing Change to TS 3.5.B.3 & Associated Bases to Extend LCO Allowable Out of Service Time for RHRSW Sys from 7 Days to 11 Days JPN-99-032, Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request1999-09-29029 September 1999 Forwards Info Re Potential Environ Effects of Alternatives to Proposed Expansion of FitzPatrick Spent Fuel Pool,In Response to NRC Project Manager Request JAFP-99-0262, Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl1999-09-16016 September 1999 Forwards Voluntary Response to Administrative Ltr 99-03, Re Preparation & Scheduling of Operator Licensing Exams. Completed NRC Form 536,containing Info Re Proposed Exam Preparation Schedule & Initial Operator License Exams,Encl JAFP-99-0258, Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld1999-09-0808 September 1999 Forwards Operator License Restriction Change for Tj Pelton, License SOP-10090-3.License Is Requested to Be Reissued with Restriction for Corrective Lenses.Encl Withheld 05000333/LER-1998-015, Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete1999-09-0808 September 1999 Forwards LER 98-015-02 Re Logic Sys Functional Test Inadequacies,Per 10CFR50.73(A)(2)(i)(B).Rept Revised to Reflect Scheduled Completion Date for Corrective Action 3 of Jan 15, 2000 & Updates Status of Other C/As as Complete JPN-99-028, Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity1999-08-30030 August 1999 Informs That Util Requires Extension from 990901 to 1015,to Complete Review of Rvid & Forward Comments to Nrc,Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity JAFP-99-0247, Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 41999-08-26026 August 1999 Forwards JAFNPP Effluent & Waste Disposal Semi-Annual Rept for 990101-0630, IAW Amend 93,App B,Section 7.3.C of Plant Ts.Format Used for Rept Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 4 JAFP-99-0245, Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 19991999-08-19019 August 1999 Informs That Two Licensed Operators Have Returned to Site Upon Release for Normal Duties by Physician.R Korthas, License OP-11159,meets ANSI Std 3.4-1983 & R Sarkissian License SOP-10007-3,was Terminated in Mar 1999 JPN-99-025, Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams1999-08-0505 August 1999 Forwards Relief Request 17 Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) for Reactor Pressure Vessel Circumferential Shell Weld Exams JPN-99-026, Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds1999-08-0505 August 1999 Forwards Relief Requests 18 & 19 to Jaf ISI Program Re Proposed Alternatives IAW 10CFR50.55a(a)(3)(i) & Relief from ASME Section XI Code Re Insp of RPV Vertical Shell & Shell to Flange Welds JAFP-99-0229, Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1)1999-07-22022 July 1999 Forwards Three Sets of Corrected Summaries of Changes for Inclusion Into Security Plan for Ja FitzPatrick Nuclear Power Plant,Rev 19 & Security Contingency Plan,Rev 5.Encls Withheld Per 10CFR73.21 & 10CFR2.790)d)(1) JAFP-99-0228, Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal1999-07-21021 July 1999 Forwards Rept Re Changes & Errors in ECCS Evaluation Models, Per 10CFR50.46(a)(3)(ii) for Period from 980701-990630.No Commitments Contained in Submittal JAFP-99-0208, Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl1999-07-14014 July 1999 Provides Clarification of Info Re Proposed Its, & 0601.Table Reconciling Differences,Encl ML20210C9031999-06-30030 June 1999 Summarizes Impact of Changes & Errors in Methodology Used by GE to Demonstrate Compliance with ECCS Requirements of 10CFR50.46.Summary of Changes & Errors Provided in Attached Table JPN-99-021, Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend1999-06-22022 June 1999 Forwards Application for Amend to License DPR-59,changing to Pressure Temp Limits.Pressure Temp Curves & Associated LCO & Bases Changes Included in Proposed Amend JPN-99-020, Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept1999-06-21021 June 1999 Submits Response to RAI Re ISI Program Relief Requests for Second 10-yr Interval Closeout & Summary Rept,Per 990426 Telcon with Nrc.Info Provided to Clarify or Withdraw Individual Relief Requests Contained in Summary Rept JPN-99-019, Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant1999-06-15015 June 1999 Withdraws Recent Exemption Request Re 10CFR50,App R, Use of Core Spray to Achieve Safe Shutdown. Exemption Dealt with Use of Core Spray for Reactor Coolant Makeup to Achieve Safe Shutdown in One Fire Area at Plant JPN-99-018, Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1)1999-06-0101 June 1999 Forwards Revised Application,Previously Submitted,For Amend to Plant TS for Converting CTS to ITS Consistent with Improved Std TS (NUREG-1433,Rev 1) JAFP-99-0171, Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr1999-05-20020 May 1999 Forwards Revised Ja FitzPatrick Nuclear Power Plant 1999 FSAR Update. Update Also Includes Changes to Chapter 17, QA Program Which Described in Attachment 1.No Commitments Contained in Ltr JPN-99-016, Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl1999-05-19019 May 1999 Forwards Application for Amend to License DPR-59,requesting 14 Day AOT for EDG Sys.Commitment Made by Util,Encl JAFP-99-0168, Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls1999-05-13013 May 1999 Forwards Eight Operator License Renewal Applications for Listed Individuals.Without Encls JAFP-99-0160, Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 41999-04-30030 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Ja FitzPatrick Nuclear Power Plant. Distribution for Rept Is IAW Reg Guide 10.1,Rev 4 ML20205T1141999-04-22022 April 1999 Provides Comments from Technical Review of Draft Info Notice Re Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station,Unit 2,ANO,Unit 2 & JAFNPP JPN-99-012, Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached1999-04-16016 April 1999 Informs That Authority Identified Typographical Error on Page 3 of Attachment 3 of 990331 Response to NRC RAI Re App R.Corrected Response to NRC Question 3 Is Attached JAFP-99-0129, Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick1999-04-0909 April 1999 Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick JAFP-99-0127, Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld1999-04-0808 April 1999 Forwards Affidavit Signed by Holtec Which Describes Proprietary Nature of Licensing Rept & Addresses Considerations Listed in 10CFR2.790.Attachment 4 in Util Re Design Features Should Be Withheld JAFP-99-0124, Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 19 to JAFNPP Security Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Safeguards Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) JAFP-99-0125, Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1)1999-04-0707 April 1999 Forwards Rev 5 to JAFNPP Security Contingency Plan,Which Enhances Requirements of 10CFR73.55.Changes Do Not Decrease Effectiveness of Plan.Plan Withheld IAW 10CFR73.21 & 2.790(d)(1) ML20205M8941999-04-0707 April 1999 Forwards Rev 21 to App C of JAFNPP Emergency Plan & Rev 1 to EAP-32, Recovery Support Group Manager JPN-99-011, Forwards Application for Amend to License DPR-59,removing Position Title of General Manager from Sections & Will Delegate Responsibilities to Another Staff Member,In Writing1999-04-0505 April 1999 Forwards Application for Amend to License DPR-59,removing Position Title of General Manager from Sections & Will Delegate Responsibilities to Another Staff Member,In Writing ML20205G4111999-03-31031 March 1999 Forwards Rev 7 to JAFNPP EP App J & Rev 6,pages 7 & 8 to EAP-5.3 05000333/LER-1999-001, Forwards LER 99-001-01 Re Incorrect EDG line-up During Fire Placing Plant in Outside Design Basis.Suppl Contains Results of Completed Root Cause Evaluations & Subsequent Corrective Actions Taken.Rept Contains No Commitments1999-03-31031 March 1999 Forwards LER 99-001-01 Re Incorrect EDG line-up During Fire Placing Plant in Outside Design Basis.Suppl Contains Results of Completed Root Cause Evaluations & Subsequent Corrective Actions Taken.Rept Contains No Commitments JPN-99-008, Forwards Application for Amend to License DPR-59,converting CTS to Be Consistent with Improved Std TS in NUREG-1433, Rev 1.Synopsis of LAR for Conversion to Its,Pending Lars, List of Subsections,Scope of Changes & Commitments,Encl1999-03-31031 March 1999 Forwards Application for Amend to License DPR-59,converting CTS to Be Consistent with Improved Std TS in NUREG-1433, Rev 1.Synopsis of LAR for Conversion to Its,Pending Lars, List of Subsections,Scope of Changes & Commitments,Encl JPN-99-010, Transmits Revised Exemption Request from Some of Requirements of 10CFR50,App R.Exemption Would Permit Use of CS for Rc Makeup to Achieve Safe Shutdown in Fire Area XI at JAFNPP1999-03-31031 March 1999 Transmits Revised Exemption Request from Some of Requirements of 10CFR50,App R.Exemption Would Permit Use of CS for Rc Makeup to Achieve Safe Shutdown in Fire Area XI at JAFNPP JAFP-99-0114, Requests That License OP-11037,for Bs Brooks,Be re-issued Without Restriction for Corrective Lenses.Nrc Form 369,encl. Without Encl1999-03-29029 March 1999 Requests That License OP-11037,for Bs Brooks,Be re-issued Without Restriction for Corrective Lenses.Nrc Form 369,encl. Without Encl JAFP-99-0112, Informs of Util Determination That Listed Individuals No Longer Need to Maintain Operating License for Ja FitzPatrick Nuclear Plant.Termination of Listed Licenses,Requested1999-03-29029 March 1999 Informs of Util Determination That Listed Individuals No Longer Need to Maintain Operating License for Ja FitzPatrick Nuclear Plant.Termination of Listed Licenses,Requested JAFP-99-0097, Forwards JAFNPP Referenced Simulation Facility Four Year Performance Testing Rept, Containing Description of Performance Testing Completed During Past Four Years & Description of Testing Scheduled During Next Four Years1999-03-17017 March 1999 Forwards JAFNPP Referenced Simulation Facility Four Year Performance Testing Rept, Containing Description of Performance Testing Completed During Past Four Years & Description of Testing Scheduled During Next Four Years ML20204B6241999-03-17017 March 1999 Forwards Plant Referenced Simulation Facility Four Year Performance Testing Rept, Per 10CFR55.45(b)ii 05000333/LER-1999-003, Forwards LER 99-003-00,per 10CFR50.73(a)(2)(i)(B).One New Commitment Is Contained in Rept1999-03-16016 March 1999 Forwards LER 99-003-00,per 10CFR50.73(a)(2)(i)(B).One New Commitment Is Contained in Rept ML20204C7371999-03-15015 March 1999 Forwards Revised EP Coversheets for Sections to Vol 1 & Rev 26,Vol 3 to EPIP SAP-10, Meteorological Monitoring Sys Surveillance JAFP-99-0085, Submits in-vessel Visual Insp Summary Rept for RFO 13 for Ja FitzPatrick Nuclear Power Plant.All Relevant Indications Recorded During Insp Were Satisfactorily Dispositioned IAW Util Internal C/A Tracking Sys & Were Found Acceptable1999-03-0808 March 1999 Submits in-vessel Visual Insp Summary Rept for RFO 13 for Ja FitzPatrick Nuclear Power Plant.All Relevant Indications Recorded During Insp Were Satisfactorily Dispositioned IAW Util Internal C/A Tracking Sys & Were Found Acceptable ML20207J3201999-03-0505 March 1999 Forwards Form NRC-369,requesting That Restriction for Corrective Lenses Be Placed on Current License SOP-10089-3, for Ks Allen.Encl Withheld Per 10CFR2.790(a)(6).Without Encl JAFP-99-0073, Submits Annual Rept on SRV Challenges & Failures,Per Plant TS 6.9.A.2.b.No Challenges to SRVs from Automatic Control Circuits or from RCS Pressure Transients,Occurred.Ltr Contains No New Commitments1999-02-26026 February 1999 Submits Annual Rept on SRV Challenges & Failures,Per Plant TS 6.9.A.2.b.No Challenges to SRVs from Automatic Control Circuits or from RCS Pressure Transients,Occurred.Ltr Contains No New Commitments JAFP-99-0071, Forwards Semi-Annual Radioactive Effluent Release Rept for Period of 980701-1231. Format Used for Effluent Data Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 41999-02-25025 February 1999 Forwards Semi-Annual Radioactive Effluent Release Rept for Period of 980701-1231. Format Used for Effluent Data Is Outlined in App B of Reg Guide 1.21,Rev 1.Distribution Is IAW Reg Guide 10.1,Rev 4 JAFP-99-0068, Forwards Form NRC-5 Equivalent Records of All Individuals Monitored at JAFNPP from 980101-1231 on Electronic Media, Per 10CFR20.2206(b) & App a of NRC Reg Guide 8.7, Instruction for Recording & Reporting..1999-02-22022 February 1999 Forwards Form NRC-5 Equivalent Records of All Individuals Monitored at JAFNPP from 980101-1231 on Electronic Media, Per 10CFR20.2206(b) & App a of NRC Reg Guide 8.7, Instruction for Recording & Reporting.. JAFP-99-0019, Informs of Licensee Intent to Upgrade ERDS at Ja FitzPatrick in Preparation for Year 2000 (Y2K) Readiness,Per GL 98-01. Encl Contains Brief Summary of Proposed Changes to ERDS1999-01-25025 January 1999 Informs of Licensee Intent to Upgrade ERDS at Ja FitzPatrick in Preparation for Year 2000 (Y2K) Readiness,Per GL 98-01. Encl Contains Brief Summary of Proposed Changes to ERDS JAFP-99-0012, Documents Util Position Re Methodology for LPRM Calibr During Reactor Operation Using Traversing In-core Probe Sys1999-01-18018 January 1999 Documents Util Position Re Methodology for LPRM Calibr During Reactor Operation Using Traversing In-core Probe Sys 1999-09-08
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Text
, White Plains, New Yori 10601 914-f>81-6840 914-287-3309 LFAX)
A NewYorkPower wou_ o. c.so,, ,,.
M80th Chief Natear Ofhter January 12,1996 JPN-96-001 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
SUBJECT:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Request for Exemption From 10 CFR 50, Appendix R Regarding Use of Low Pressurejojection_ Systems to Achieve Safe ShutdnWB
REFERENCE:
NRC letter, C. E. Carpenter, Jr. to W. J. Cahill, Jr., dated September 5, 1995, regarding " Safety Evaluation of Safe Shutdown Capability i Reassessment for James A. FitzPatrick Nuclear Power Plant" (TAC No.
M84780)
Dear Sir.
This letter transmits an exemption request to allow the use of low-pressure injection systems to achieve safe shutdown in six fire areas. An exemption request for five fire areas was recommended in the Reference letter. The Authority is requesting an exemption for the sixth fire area to ensure consistent licensing basis for the fire protection rule at the FitzPatrick Plant. This request satisfies the criteria of 10 CFR 50.12 as described in the Attachment to this letter.
If you have any questions, please contact Ms. C. D. Faison.
Very truly yours, 160rPn William J. ahill, Jr.
Chief Nuclear Officer cc: Next Page 9601160375 960112 gDR ADOCKOS00g3 g gf lj ,
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Attachment:
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. C. E. Carpenter, Project Manager Project Directorate I-1 Division of Reactor Projects - 1/11 l
U.S. Nuclear Regulatory Commission Mail Stop 14B2 Washington, DC 20555 l i
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, ATTACHMENT TO JPN-96-001 l
REQUEST FOR EXEMPTION FROM 10 CFR 50, APPENDIX R REGARDING USE OF LOW PRESSURE INJECTION SYSTEMS TO ACHIEVE SAFE SHUTDOWN MALUATION PURSUANT TO 10 CFR 50.12 CRITERIA l l
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JAMES A. FlTZPATRICK NUCLEAR POWER PLANT NEW YORK POWER AUTHORITY JANUARY 12,1996 f
. ATTACHMENT TO JPN-96-001
1.0 INTRODUCTION
The Authority is requesting an exemption from the requirements of 10 CFR 50, Appendix R as they apply to the James A. FitzPatrick Nuclear Power Plant so that low-pressure injection systems may be used to achieve safe shutdown in six fire areas.
An exemption request for five fire areas was recommended by the NRC letter dated September 5,1995. The Authority is requesting an exemption for the sixth fire area to ensure consistent licensing basis for the fire protection rule at the FitzPatrick Plant.
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2.0 BACKGROUND
By letter dated October 26,1992 and supplemented by letter dated July 22,1994, the Authority submitted the FitzPatrick Safe Shutdown Capability Reassessment (Reference 7.1). This report detailed the Authority's four methods (Methods 1,2,3, and 4) for achieving hot shutdown in the event of a fire.
By letter dated September 5,1995 (Reference 7.2) the NRC transmitted its safety evaluation of the FitzPatrick Safe Shutdown Capability Reassessment. In this letter, the NRC concluded that the Authority's Method 3, use of Low-Pressure injection Systems (LPIS), does not satisfy the requirements of Appendix R for five fire areas (IX, X, XI, XVil, and XVill). The specific issues are (1) the use of LPIS does not meet the technical requirements of Section Ill.G.1 of Appendix R, to the extent that LPIS will not allow hot shutdown conditions to be maintained, and (2) the use of LPIS does not satisfy the shutdown system performance criteria of Section Ill.L of Appendix R. As a result of these issues, the NRC recommended that the Authority seek an exemption for the five fire areas.
By letter dated September 10,1992 (Reference 7.6) the NRC issued a revised exemption from the requirements of 10 CFR 50, Appendix R, Sections Ill.G.2, Ill.G.3, and Ill.L such that neither separation of redundant safe shutdown circuits nor altemate shutdown capability is required for the Torus Room (Fire Area XV). The Authority's associated exemption request (Reference 7.9) stated that the High Pressure Coolant Injection and Reactor Core isolation Cooling Systems would be considered disabled for a postulated fire in the Torus Room and that LPIS would be available for safe shutdown. However, the Authority did not explicitly request an exemption to allow use of LPIS; therefore the Authority is also including the Torus Room in this exemption request to allow the use of LPIS to achieve safe shutdown.
3.0 EXEMPTION REQUEST in accordance with the provisions of 10 CFR 50.12(a), the New York Power Authority requests an exemption from the requirements of 10 CFR 50, Appendix R, Sections Ill.G.1, Ill.L.1, and Ill.L.2 as they apply to the James A. FitzPatrick Nuclear Power Plant so that LPIS may be used to achieve safe shutdown for Fire Areas IX, X, XI, XV, XVil, and XVill.
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, ATTACHMENT TO JPN-96-001 Fire Areas / Fire Zones Affected Fire Area Fire Zone Area Description IX RB-1 A Reactor Building East Side - El. 272'; Southeast Quadrant - El. 300'; and Entire Floor - El. 326',
344', and 369' 1
SG-1 Standby Gas Filter Room - El. 272' l 1
X RB-1 B Reactor Building West Side - El. 272' and Southwest Quadrant - El. 300' XI CT-3 South Cable Tunnel - El. 286' XV SU-1 Torus Room XVil RB-1 E Reactor Building East Crescent Area - El.
227' XVill RB-1W Reactor Building West Crescent Area - El. 227' 4.0 PHYSICAL ARRANGEMENT AND FIRE PROTECTION FEATURES Subsections 4.1 through 4.6 provide a description of each fire area, along with fire detection and suppression capability. The term "three-hour fire rated barriers" as used in these subsections includes unrated and/or unsealed penetrations that were evaluated and determined to be adequate in accordance with NRC Generic Letter 86-10 (Reference 7.4).
Based on the types and amounts of combustibles in Fire Areas IX, X, XI, XVil, and XVill, and the administrative control of combustibles, the detection and suppression capability is adequate to provide early detection and extinguishment of the anticipated fire. The detection and suppression systems alarm both visually and audibly in the Control Room thereby providing reasonable assurance that a fire would be detected in its initial stages before significant damage occurred. The fire would be extinguished either by the automatic suppression systems or by the fire brigade using manual fire fighting equipment. If the fire propagated beyond the immediate point of origin, the walls, floors and ceilings would confine the damage to the affected zone. At the common fire zone boundaries where no physical barriers exist, the water spray curtain systems will prevent fire spread into the horizontally or vertically adjoining fire zones.
Based on the types and amounts of combustibles in Fire Area XV and the administrative control of combustibles, the anticipated fire is expected to be contained within the Torus and not jeopardize safe shutdown capability.
Page 3 of 9 l
. ATTACHMENT TO JPN-96-001 4.1 Fire Area IX Fire Area IX consists of Fire Zones RB-1 A and SG-1. Fire Zone RB-1 A includes Reactor Building East Side, Elevation 272'; Reactor Building Southeast Quadrant, Elevation 300'; and the 326',344', and 369' Elevations of the Reactor Building. Fire Zone SG 1 encompasses the Standby Gas Filter Room on Elevation 272' of the Reactor Building.
Automatic water spray curtain systems, approved for use by exemption to the requirements of Appendix R (Reference 7.3), and three-hour fire rated barriers separate Fire Zone RB-1 A from adjacent fire zones. Manually activated water spray suppression systems are provided for Standby Gas Filter Trains A and B in Fire Zone SG-1. Manual fire hose stations and portable fire extinguishers are provided for both fire zones.
lonization smoke detectors provide area-wide coverage for Fire Zone SG-1 and provide coverage for areas containing safe shutdown equipment in Fire Zone RB-1 A.
Additional fire detection capability is provided by rate compensated heat detectors for each filter plenum in the Standby Gas Filter Room. Local rate compensated heat detectors actuate the water spray curtains in Fire Zone RB-1 A.
4.2 Fire Area _X Fire Area X consists of a single Fire Zone, RB-1B. Fire Zone RB-1B includes the Reactor Building West Side, Elevation 272'; and the Reactor Building Southwest Quadrant, Elevation 300'.
Automatic water spray curtain systems, approved for use by Reference 7.3, and three-hour fire rated barriers separate Fire Zone RB-1B from adjacent fire zones. Manual fire hose stations and portable fire extinguishers are provided for Fire Zone RB-18.
Area-wide coverage by ionization smoke detectors is provided for Fire Zone RB-18.
Local rate compensated heat detectors actuate the water spray curtains.
4.3 Fire Area XI Fire Area XI consists of a single Fire Zone, CT-3, which encompasses the South Cable Tunnel, Elevation 286'.
Automatic total flooding CO2 fire suppression is provided for Fire Zone CT-3. Manual suppression capability is provided by a portable fire extinguisher and a fire hose station.
Area-wide coverage by ionization smoke detectors and rate compensated heat detectors is provided for Fire Zone CT-3. The heat detectors also actuate the suppression system.
Page 4 of 9
R
. ATTACHMENT TO JPN-96-001 4.4 Fire Area XV Fire Area XV consists of a single Fire Zone, SU-1, which encompasses the Torus ,
Room, Elevation 227'. l l
The Torus Room has neither an automatic fire detection system nor an automatic fire suppression system. Due to the area configuration and the combustible loading, this area was exempted (Reference 7.6) from the requirements necessitating these systems. Manual fire suppression capability is provided by fire hose stations.
4.5 Fire Area XVil 4 Fire Area XVil consists of a single Fire Zone, RB-1E, which encompasses the Reactor l Building East Crescent Area, Elevation 227'.
Automatic water spray curtain systems, approved for use by Reference 7.3, and three-hour fire rated barriers separate Fire Zone RB-1E from adjacent fire zones. Fire suppression for the High Pressure Coolant injection (HPCI) pump and turbine is l provided by an automatic water spray system and a manually activated foam fire suppression system. Manual fire suppression capability is provided by a manual fire hose station and portable fire extinguishers. In addition, certain design features of the HPCI System, such as shielding of the turbine casing, insulated piping, and trouble alarms, reduce the likelihood of a lubricating oil fire.
Area-wide coverage by ionization smoke detectors is provided for Fire Zone RB-1E.
Local rate compensated heat detectors actuate the HPCI water spray system and water spray curtain systems.
4.6 Fire Area XVill Fire Area XVill consists of a single Fire Zone, RB-1W, which encompasses the Reactor Building West Crescent Area, Elevation 227'.
An automatic water spray curtain system, approved for use by Reference 7.3, and three-hour fire rated barriers separate Fire Zone RB-1W from adjacent fire zones. The physical arrangement and fire protection features associated with the HPCI pump and turbine, which straddles the boundan/ of Fire Zones RB-1E and RB-1W, are described in Subsection 4.5. Fire suppression for the Reactor Core Isolation Cooling (RCIC) pump and turbine is provided by an automatic water spray system. Manual fire suppression capability is provided by a manual fire hose station and portable fire extinguishers. In addition, certain design features of the RCIC System, such as insulated piping and trouble alarms, reduce the likelihood of a lubricating oil fire.
Area-wide coverage by lonization smoke detectors is provided for Fire Zone RB-1W.
Local rate compensated heat detectors actuate the RCIC water spray system and water spray curtain systems.
Page 5 of 9
'. ATTACHMENT TO JPN-96-001 5.0 JUSTIFICATION FOR EXEMPTION 10 CFR 50.12(a) states that the Nuclear Regulatory Commission may grant exemptions from the requirements of the regulations contained in 10 CFR 50 provided that:
a The exemption is authorized by law; e The exemption does not present an undue risk to the public health and safety; e The exemption is consistent with the common defense and security; a Special circumstances are present as defined in 10 CFR 50.12(a)(2).
The requested exemption satisfies the 10 CFR 50.12 criteria as stated below:
A. The requested exemption is authorized by law.
10 CFR 50.12(a) authorizes the Nuclear Regulatory Commission to grant this exemption.
B. The requested exemption does not present an undue risk to the public health and safety.
Section Ill.G.1.a of 10 CFR 50, Appendix R requires one train of systems necessary to achieve and maintain hot shutdown conditions to remain free of fire damage. Additionally, the safe shutdown system performance criteria specified in Sections Ill.L.1 and Ill.L.2 of Appendix R require, in part, that during the post-fire shutdown, the reactor coolant makeup function be capable of maintaining reactor coolant level above the top of the core.
High-Pressure injection Systems (HPIS) would normally be used to achieve and maintain hot shutdown in the event of a fire in Fire Area IX, X, XI, XV, XVll, or XVill. In the unlikely event that a fire in one of these fire areas prevented use of the HPIS, LPIS would be used to achieve and maintain cold shutdown. Section Ill.G.1 of 10 CFR 50, Appendix R requires that at least one train of systems necessary to achieve and maintain hot shutdown be free of fire damage, and at least one train of systems necessary to achieve and maintain cold shutdown be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Hot shutdown duration was discussed in NRC Generic Letter 86-10 (Reference 7.4) in response to Question 5.3.3 (Generic Letter 86-10, Enclosure 2, Page 23). The response states:
I "Section Ill.G.1 requires that the one train of systems needed to achieve and i maintain hot shutdown be free of fire damage. Thus, the systems needed are to l be completely protected from the fire regardless of time. If the intent of the question concerns how long these systems must operate, these systems must be capable of operating until systems needed to achieve and maintain cold i I
shutdown are available."
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. ATTACHMENT TO JPN-96-001 This response is consistent with the ultimate objective of Appendix R which is safe shutdown, i.e. cold shutdown. There is no need to, or safety benefit associated with, maintaining hot shutdown for any longer than necessary to restore cold shutdown capabinty. At FitzPatrick, the availability of LPIS is assured in the event of a fire in Fire Area IX, X, XI, XV, XVil, or XVill due to the fire protection features present and the physical configuration of the plant; therefore, fire safety is not enhanced by assuring the availability of HPIS.
As discussed above, LPIS would only be used when HPIS are unavailable.
Although the use of LPIS could result in short-term uncovering the core, this condition does not pose a threat to fuel cladding integrity and has been previously evaluated and approved by the NRC.
By letters dated September 15,1986 (Reference 7.5) and September 10,1992 (Reference 7.6) the NRC issued exemptions which permitted the reactor coolant level to drop below the top of the core during the use of alternate safe shutdown procedures following control room evacuation. The basis for these exemptions was an analysis which demonstrated that the short-term core uncovering due to delayed operator actions would not challenge fuel cladding integrity. The analysis is bounding for the short-term core uncovering that could occur in the event of a fire in Fire Area IX, X, XI, XV, XVil, or XVill concurrent with a complete loss of high pressure makeup capability.
In addition to FitzPatrick-specific exemptions, the NRC has previously evaluated BWR short-term core uncovering during the use of LPIS. NRC Memorandum from L. S. Rubenstein to R. J. Mattson (Reference 7.7) indicates that the uncovering time is short enough and the amount of fuel uncovered is small l enough, that cladding integrity would not be threatened. Furthermore, NRC I Inspection Procedure 64100 (Reference 7.8) Section 02.01.a.2 indicates that the NRC has approved short-term core uncovering while using LPIS, and that the use of LPIS eliminates the need to maintain hot shutdown conditions. ,
Therefore, the requested exemption does not present an undue risk to the public health and safety.
C. The requested exemption is consistent with the common defense and security.
The common defense and security are not affected by this exemption request.
Page 7 of 9
. ATTACHMENT TO JPN-96-001 D. Special circumstances are present as defined in 10 CFR 50.12(a)(2).
10 CFR 50.12(a)(2) states, in part: "The Commission will not consider granting an exemption unless special circumstances are present. Special circumstances are present whenever ..... (ii) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is it necessary to achieve the underlying purpose of the rule; or (iii) Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess i of those incurred by others similarly situated."
This exemption request satisfies criterion (ii) of 10 CFR 50.12(a)(2) in that the use of LPIS will assure safe shutdown is achieved and maintained, and will not I pose a threat to fuel cladding integrity; and the modifications necessary to assure I the availability of HPIS would not enhance fire safety above that provided by existing fire protection.
l This exemption request satisfies criterion (iii) of 10 CFR 50.12(a)(2) in that the )
high cost associated with modifications to assure the availability of HPIS would present undue financial hardship to the Authority.
6.0 CONCLUSION
The Authority concludes that this exemption request is warranted under the provisions of 10 CFR 50.12, in that it is authorized by law, does not present an undue risk to the public health and safety, is consistent with the common defense and security, and special circumstances are present.
7.0 REFERENCES
7.1 Safe Shutdown Capability Reassessment 10 CFR 50 Appendix R, James A. FitzPatrick Nuclear Power Plant, November 1992 7.2 NRC letter, C. E. Carpenter, Jr. to W. J. Cahill, Jr., dated September 5,1995, regarding " Safety Evaluation of Safe Shutdown Capability Reassessment for James A.
FitzPatrick Nuclear Power Plant" 7.3 NRC letter, Domenic B. Vassallo to Corbin A. McNeill, dated January 11,1985, regarding " Exemptions Requests - 10 CFR 50.48 Fire Protection and Appendix R to 10 CFR Part 50" 7.4 NRC Generic Letter 86-10, implementation of Fire Protection Requirements 7.5 NRC letter, Robert M. Bernero to John C. Brons, dated September 15,1986, regarding
" Exemption From Appendix R to 10 CFR 50 Concerning Core Uncovery During Altemate Safe Shutdown" 7.6 NRC letter, Robert A. Capra to Ralph E. Beedle, dated September 10,1992, regarding
" Issuance of Exemptions From Requirements of 10 CFR Part 50, Appendix R, for the James A. FitzPatrick Nuclear Power Plant" Page 8 of 9
m_.. _ . . _ _. .__ _ _ . . . . . . _ _ . - . _ . _ . _ . _ _ . _ . _ . _ . _ . . . . _ . . . _ . _ . . . _ _ _ _ . . . . . . _ . . _ _ _ _.. .
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. ATTACHMENT TO JPN-96-001 j 7.7 NRC Memorandum, L. S. Rubenstein to R. J. Mattson, dated December 3,1982,
< regarding "Use of the Automatic Depressurization System (ADS) and Low Pressure ,
Coolant Injection (LPCI) to Meet Appendix R, Alternate Shutdown Goals" '
7.8 NRC Inspection Procedure 64100, Postfire Safe Shutdown, Emergency Lighting and ,
Oil Collection Capability at Operating and Near-Term Operating Reactor Facilities 3
7.9 NYPA letter JPN-92-043, Ralph E. Beedle to NRC, dated July 31,1992, regarding i " Revision to Exemption From 10 CFR 50, Appendix R" i
Page 9 of 9
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