ML20092P368

Advises That Plant Recombiner Capability Not Required Per Criteria Discussed in Generic Ltr 84-09.Review of Mark I Owners Group Generic Study Determined Recombiner Not Required for BWRs W/Inerted Containments

ML20092P368
Person / Time
Site:	FitzPatrick
Issue date:	06/29/1984
From:	Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Vassallo D Office of Nuclear Reactor Regulation
References
GL-84-09, GL-84-9, JPN-84-43, NUDOCS 8407060214
Download: ML20092P368 (3)

Text

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June 29, 1984 JPN-84-43 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20556 Attention: Mr. Domenic B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing Sub]ect: James A. FitzPatrick (JAP) Nuclear Power Plant Docket No. 50-333 Generic Letter 84-09 Recombiner Capability Requirements of 10 CFR 50.44(c)(3)(ii)

References:

1. NYPA letter, J. P. Bayne to D. B. Vassallo, dated June 29, 1983 (JPN-83-59).

2. BWROG letter, T. J. Dente to T. G. Eisenhut, dated June 21, 1982 - transmittal of Owners' Group technical position (NEDO-22155).

Dear Sir:

The New York Power Aathority (NYPA) has determined that according to the criteria presented in Generic Letter 84-09, a recoubiner capability is not required for the JAF facility.

As has been discussed previously in Reference 1, we have reviewed the generic study of combustible gas control sub-m2tted by the Mark I Owners Group (Reference 2), and have cetermined that it is applicable to our FitzPatrick tacility. The results of c' his generic study show that, for all BURS with inerted Mark I containments, peak containment oxygen concentrations are maintained below the combustible gas.11mits at all times without requiring containment venting or hydrogen recombiners.

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JAF Technical Specifications (T.S.3.7.A 6, pg. 180) require i drywell inerting to 4 4% oxygen during power operation. JAP {

uses the change of mode switch position from STARTUP to RUN  ;

as the point where inerting must be. complete within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. JAF also starts to de-inert up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to the mode switch being shifted out of RUN (based on the estimated time the mode switch will be shifted). During operation it is normal practice to maintain the oxygen

- concentration in the drywell in a range of 2% to 3%.

During power operation when the primary containment is inerted, the crywell to suppression chamber differential pressure is maintained at least 1.7 psid. Nitrogen is periodically added to the drywell in order to make up for any leakaye during surveillance testing of vacuum breakers and any other leakage through penetrations or sample lines.

Other than the oxygen resulting from radiolysis of the reactor coolant, the following potential sources of oxygen in containment have been considered:

1. Instrumentation f

JAF drywell instrumentation (safety relief-valves, main steam line isolation valves, drywell cooler dampers and transversing incore probe purge) has the capability to use either nitrogen or air. Although nitrogen is normally used when the drywell is inerted, present procedures do not require that only nitrogen be used.

The Authority will, therefore, revise the scram and isolation recovery procedures to require that only nitrogen be used when possible during normal and post-isolation conditions. These procedures are scheouled to be revised by July-31, 1984.

2. Service Air & Breathing Air To prevent air inleakage through-the. service air and breathing air penetrations, the fol' lowing verifica-tions are performed:

a. The Startup and Shutdown procedure specifically states to perform surveillance procedure ST-15H

" Primary Containment Integrity Manual-Isolation Valve Position Verification" and verify the service air.and breathing air quick disconnects are disconnected before increasing to rated power.

b. ST-15H' verifies that the isolation valves for breathing and service air are closed and again that the disconnects are removed.

c. In the startup/ shutdown procedure, each. system's valve lineup, raust be checked against its specific operating procedure in which, again, the. isolation valves are verified closed.

J Although service air and breathing air are normally disconnected, current JAF procedures do not require isolation valves to be locked shut. Procedures will, therefore, be revised to require locking of the valves.

Tnese revisions are scheduled to be completed by July 31, 1984.

3. Instrument Air This is discussed above.

4. Electrical Penetrations These are pressurized with dry nitrogen.

FitzPatrick has no inflatable door seals or air-pressurized HSIV leakage control system.

If you have any questions, please contact Mr. J. A. Gray, Jr.

ot my staff.

Very truly yours, J.

4W P. Bayne Executive-Vice President Nuclear Generation cc: Utfice of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, New York 13093