ML19262C112

Response to Show Cause Order Re Implementation of Lessons Learned Task Force Category a Requirements.Util Has Complied W/All Requirements Except 2.1.4.2,due to Unavailability of Equipment.Affirmation of Pj Early & Certificate of Svc Encl

ML19262C112
Person / Time
Site:	FitzPatrick
Issue date:	01/22/1980
From:	Frey T POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC COMMISSION (OCM)
Shared Package
ML19262C111	List: ML19262C110 ML19262C112
References
RTR-NUREG-0578, RTR-NUREG-578 NUDOCS 8001280332
Download: ML19262C112 (8)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of l POWER AUTHORITY OF THE STATE [

Docket No. 50-333 OF NEW YORK ,

(James A. FitzPatrick Nuclear  !

Power Plant) ,

POWER AUTHORITY OF THE STATE OF NEW YORK'S ANSWER TO ORDER TO SHOW CAUSE REQUIRING IMPLEMENTATION OF CATEGORY "A" REQUIREMENTS FOR THE JAMES A. FITZPATRICK NUCLEAR POWER PLANT On January 2, 1980 the Nuclear Regulatory Commission's Director of the Office of Nuclear Reactor Regulation issued an order to show cause requiring that the Power Authority of the State of New York (" Authority") demonstrate why, by January 31, 1980, it should not implement all of the " Category A" require-ments of NUREG-0578 as supplemented by the Nuclear Regulatory Commission's ("Commis sion 's " ) letters dated September 13, 1979 and October 30, 1979.

The Authority submits that it has complied with all such applicable requirements as of January 1, 1980, except for require-ment 2.1.3.a which concerns installation of equipment to provide a direct indication of pressure relief valve position. With respect to this requirement, the Authority has ordered the necessary equip-ment but it is not presently available. The Authority expects that the nectasary equipment will be available in March 1980.

1816 273' 8001280

. RESPONSE TO THE ORDER TO SHOW CAUSE With respect to the allegations of Paragraph I of the order to show cause, the Authority admits each of the allegations.

With respect to the allegations of Paragraph II, the Authority admits each of the allegations, except the Authority denies knowledge or information sufficient to admit or deny what the Commission has concluded concerning prompt implementation of certain actions.

With respect to the allegations of Paragraph III, the Authority admits each of the allegations insofar as they apply to the Authority and denies knowledge or information sufficient to respond to the allegations as they affect or apply to other licensees. The Authority expects, based on its current information and the undertakings made to it by vendors and contractors, that a thirty day period after delivery of equipment is a reasonable and practical time to complete installation of such equipment and that all equip-in quest,on should be delivered and installed by June 1, 1980.

The Authority denies knowledge or information sufficient to respond to the allegation that implementation by January 31, 1980 is necessary to provide continued assurance of public health and safety.

With respect to the allegations in Paragraph IV,

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the Authority respectfully refers the Commission to the following demonstration:

1816 274'

DEMONSTRATION OF UNAVAILABILITY OF NECESSARY EQUIPMENT Equipment

Description:

The Authority has purchased a safety relief valve monitoring system from Babcock and Wilcox, Power Generation Division ("B&W"). The system consists of an acoustical monitor mounted on each valve, a charge amplifier, signal conditioning equipment and a control cabinet to be located in the control room. Associated cabling has been purchased separately.

Equipment Fabrication and Delivery:

The critical path item in fabrication of the monitor-ing system is the control cabinet. The Authority has been informed by B&W that the cabinet is NEMA 12 design, manufac-tured by Hoffman Engineering Company and will be qualified to IEEE-344. The earliest anticipated receipt of the cabinet by B&W is February 23, 1980. B&W must install the electrical components and wiring in the cabinet and ship it to the site.

On this basis, B&W's earliest estimate of date of delivery is March 15, 1980. A copy of a letter to the Authority from B&W detailing B&W's schedule is attached as Exhibit "1". The Authority is monitoring the progress of B&W and where possible will continue to expedite fabrication and delivery.

Installation:

The Authority will install the direct relief valve indication system within 30 days of receipt of the equipment unless it appears that the 1980 refueling outage will begin within the 30 days. If this should occur, the installation 1816 215

_4 will be scheduled consistent with other outage activities and will be completed prior to plant start-up.

Public Health and Safety Implications:

The Authority has proposed a reasonable schedule for implementing the relief valve indication system and believes that, pending installation, public health and safety are adequately protected because of the following considerations:

1. The relief valves at the FitzPatrick plant serve the safety functions of overpressure protection and backup to a single high pressure coolant injection system. Therefore, they are not isolable. Post accident or post-event response by operators of a BWR are chiefly governed by reactor vessel level instrumentation in order to assure core coverage. Such instrumentation was not present in the PWR design of TMI.

2. At the FitzPatrick plant there currently are temperature elements at each relief valve discharge which give indication of individual relief valve opening and which can give indication of slow leak-ages through temperature trend analyses.

3. The Authority's procedures for stuck open relief valves and small break LOCA's can be implemented without the proposed relief valve indication system.

4. Relief valves in BWR's are frequently used in miti-gating plant transients. The Authority's letter 1816 276

to the Commission dated October 22, 1979 provided a history of events where relief valves have stuck open. In each of the 50 events the reactor was depressurized, the stuck valve was repaired or replaced and the plant placed back into service.

At the James A. FitzPatrick plant eight (8) out of eleven (11) relief valves have been modified to a design which has a history of being less susceptable to being stuck open and the remaining three (3) will be modified during the 1980 re-fueling outage.

WHEREFORE, the Authority believes that it has complied with all of the requirements of the order to show cause for the James A. FitzPatrick plant. All of the " Category A" requirements of NUREG-0578 have been met with the exception of the installation of positive indicators for the safety relief valves. The positive indicators,which are currently unavailable, will be installed within thirty (30) days of receipt of materials.

In the event that the plant is shut down for refueling prior to termination of the thirty (30) day period, installation of the positive indicators will be completed prior to re-starting the plant. Should the Commission require implementation on a schedule other than as set forth in this answer, the Authority.

reserves its right to request a hearing on such schedule. ,

Re,spectfully s,ubmitted 1816 277 THbShS R. F5E '

General Counsel Power Authority of the State of New York January 22, 1980 10 Columbus Circle New York, New York 10019 (212) 397-6200

EXHIBIT I Babcock & Wilcox  %,c~.mc.

P.o. Bos 3200. Lynchburg, Va. 24505 Tekvene:(Go4)384-5111 January ll, 1980

'a M&

&cwer Authority State of New York L 10 Colunbus Circle New York, NY 10019 Subjcct: Valve Monitoring System PASNY order no. 19083-79 B&W no. 600-5206 Delivery Infomation Attention: Mr. Tom Hannan

Dear Mr. Hannan:

The delivery of the subject Valve Monitoring System is being controlled by the following factors: -

- NEMA-12 cabinet - B&W has ordered NEMA-12 cabinets from Hoffman Engineering Company of Anoka, Minnesota. This cabinet was chosen to benefit from pre-viously perfonted seismic tests. Delivery of this cabinet is due in late February.

An NiC0 cabinet could be used however, this cabinet has not been tested and all plans to test equipment in the near future is based on the use of the Hoffman NEMA-12 equipment.

- Subsequent to receipt of the cabinet B&W will require approximately three weeks for assembly.

- The edgemeters are also long lead items, however, the rneters can be installed in the field after shipment.

B&W is targeting delivery of the subject hardware between March 15, 1980,,

and March 30, 1980.

Please advise if you require further infomation on this subject.

Very truly yours, THC BABC0CK & WILCOX COMPANY M ~

J. M. Brunke iojr 37o Pr9 duct Manager 80iu ci U JMB/kjb The Batcoth & Witox Comyny I rey! het! IBM

AFFIRMATION State of New York )

) ss County of New York )

The undersigned PAUL J. EARLY, being duly sworn, hereby deposes and affirms as follows: that he is the Assistant Chief Engineer-Projects of the Power Authority of the State of New York; that he has read the foregoing Answer To Order To Show Cause Regarding Implementation of Category A Requirements of NUREG 0578 for The James A. FitzPatrick Nuclear Power Plant; and that the facts set forth therein are true and correct to the best of his knowledge, information and belief.

Dated: January 22, 1980.

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PAU /J. EARLYf Subscribed and sworn to before me this 22nd day of January 1980.

4d 3 Notafy~ Publib g // g -

RUTH G. ZAPF Notary Public. State of New York No. 30 4C6M23 coM[sNNd"ctIe*sSia"rc$b l0}h 2[h My Commission expires:

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UNITED STATES OF AMERIC4 NUCLEAR REGULATORY COMMISSION In the Matter of )

Power Authority of the )

State of New York ) Docket No. 50-333 James A. FitzPatrick ) O.L. No. DPR - 59 Nuclear Power Plant )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Power Authority of the State of New York's Answer to the Order to Show Cause Regarding Implementation of Category A Requirements For The James A. FitzPatrick Nuclear Power Plant have been mailed first class, postage prepaid, this 22nd day of January 1980 to each of the following:

Harold P. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 (1) original +

(20) copies Samuel J. Chilk Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 (1) copy Howard K. Shapar, Esq.

Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 (1) copy

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By M7 ' j~ ~

Angel Power A/u.Mirtin,Esq.

thority of the State of New York 18115 280~