JPN-88-019, Discusses Main Control Room Emergency Ventilation Sys (Mcrevs) Tech Specs.Generic Ltr 83-36 (NUREG-0737 Tech Specs Specs) Does Not Require Adoption of Sts.Util Will Submit Amend to Reduce Mcrevs Allowable Outage Times to 14 Days
| ML20154F692 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/13/1988 |
| From: | Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM GL-83-36, JPN-88-019, JPN-88-19, NUDOCS 8805240036 | |
| Download: ML20154F692 (3) | |
Text
U3 Wo Ore +1 V.hte Pl+ns, New Wr k 1N01 9M f4it 620
- > NewYorkPower
-ce-4# Authority ll C a d " * "'
May 13, 1988 JPN 019 U. S.
Nuclear Regulatory Commission Attn. Document Control Desk Washington, D.
C.
20535
Subject:
James A.
FitzPatrick Nuclear Power Plant Docket No. 50-333 Main Control Room Emergency Ventilation System Technical Soecifications
References:
1.
NRC letter, H. Abelson to J.
C.
Brons dated February 17, 1988, regarding Amendment 114 to Technical Specifications.
2.
NYPA letter, J.
C.
Brons to D.
R.
Muller dated December 19, 1986, (J PN-8 6-059 )
regarding NUREG-0737, Item III.D.3.4, "Control Room Habitability Requirements."
Dear Sir:
In Reference 1, the NRC staff approved an amendment to the FitzPatrick Technical Specifications that requires capacity testing of the Main Control Room Emergency Ventilation System (MCREVS) every eighteen months.
That letter further requested that the Authority propose revised Limiting Conditions for Operation (LCOs) for the MCREVS filters or justify an alternative LCO.
Reduced allowable outage times (LCOs) for the FitzPatrick MCREVS would not increase safety nor reduce risk.
As demonstrated in Reference 2, existing specifications are already comparable with, and in some cases more restrictive than, the NRC's Standard Technical Specifications (STS).
FitzPatrick's MCREVS filters have had an excellent availability record.
A review of work request records demonstrates a 100 percent availability for the three-year period ending December 31, 1987 (i.e. at no time during this period were both filter trains unavailable).
The worst-case availability (for a single train) was approximately 99.75 percent.
The 0.25 percent unavailability is solely attributable to removing the system from service for planned maintenance (7 to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> per pool 8805240036 880513 PDR ADOCK 05000333 1 0 p
a system from service for planned maintenance (7 to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> per year per filter train) and surveillance testing to comply with Technical Specifications (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per year per train).
No failures or corrective maintenance were recorded during this period.
Generic Letter 83-36 (NUREG-0737 Technical Specifications) does not require adoption of STS.
The Generic Letter stated thet the "sample" STS included in Enclosure 3 were "for your information only."
Clearly, STS are guidance, not requirements.
In as much as the LCOs included in the STS are not based on an engineering assessment or developed through a quantifying methodolog'/, compliance with them may not represent an improvement in plant operations.
Existing FitzPatrick LCOs and surveillance requirements have been exhaustively justified.
They are adequate to assure the continued health and safety of the public.
i Despite this, the Power Authority will submit a proposed license amendment to reduce MCREVS allowable outage times to fourteen days with one filter train incperable, and three days with both trains inoperable.
If you or your staff have any questions concerning this matter, please contact Mr. J. A. Gray, Jr. of my staff.
Very truly yours,
/1 ohn C.
Brons Executive Vice President Nuclear Generation cc: U. S. Nuclear Regulatory Commission Region 1 475 Allendale Road l
King of Prussia, Pennsylvania 19406
]
Mr. Harvey Abelson Project Directorate I-1 Division of Reactor Projects - I/II U. S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, D.C.
20555 I
P f
i l
i 4
cc (cont'd) i, Office of the Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 136 4
Lycoming, New York 13093 4
1 s
f a
N f
n
)
I T
I
.f I
4 d
9 i
a i
4
'l 4
d i
j e
'l b
I l
i, ii l
t'
\\
i 7
1 4
m
-n-
,_g,
--,,,,7.-,
w,,,,m,-e.