ML20100J722

Submits Addl Info Re 850315 Request for Schedular Exemption from Requirements of 10CFR50,App R,Section Iii.G.Significant Portion of Work Can Only Be Done During Plant Outage Due to Equipment Location.Fire Watch Will Be Implemented

ML20100J722
Person / Time
Site:	FitzPatrick
Issue date:	04/05/1985
From:	Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Vassallo D Office of Nuclear Reactor Regulation
References
JPN-85-26, NUDOCS 8504110195
Download: ML20100J722 (3)

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4# Authority April 5, 1985 JpN-85 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Domenic B. Vassallo, Chief Operating Reactors Branch'No. 2 Division of Licensing

Subject:

' James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Additional Information regarding Appendix R to 10 CFR 50 Schedular Exemption Request

References:

-l. NYPA letter, C. A. McNeill, Jr. to D. B. Vassallo, dated March 15, 1985 (JPN-85-21) regarding Appendix R to 10 CPR 50 - Request for Schedular Exemption.

Dear Sir:

In our March 15, 1985 letter (Reference 1), the Authority requested a schedular exemption from the requirements of Section III.G of Appendix R to.10 CFR 50. This exemption is necessary to complete the engineering, purchase the necessary equipment and install the long' term corrective modifications described in Reference 1. These

-modifications involve the addition of redundant fuses for the alternate shutdown system.

During~the past weeks, we have had several telephone discussions with members of your staff about our request. This letter provides clarification as to why these long-term modifications cannot be completed sooner and describes an additional compensatory measure that will be implemented until the modifications are completed.

Schedule Justification A significant portion of the work required to install these modifications can only be done during plant outages because of the equipment's location or operating requirements associated with the equipment (i.e. Technical Specification Limiting Conditions for Operation).

The design and engineering of these modifications will require between four and six months. Included in this work is the revision of approximately 110 plant drawings: preparation of

. procurement specifications for Class lE electrical cable, relays and other equipment: design of new conduit runs between 8504110195 850405 ph PDR ADOCK 05000gj3

alternate shutdown panels and motor control centers: and the design of seisv..cally qualified conduit supports. An additional month is requitsd for the review and final approval of the engineering drawings and specifications.

.We estimate that approximately five months is necessary to procure all the requisite materials and components after procurement specifications have been issued. Lead time for Class 1E relays is currently 12 to 16 weeks: Class 1E cable requires 16 to 20 weeks.

Using these estimates, installation cannot be started for 10 to 12 months. This schedule was prepared assuming that contracts will be awarded sole source (i.e. no competitive bidding).

Additional time will be required if competitive bids are necessary.

Compensatory Measures In lieu of the interim measures and procedures described in Section 3.0 of Attachment No. 1 to Reference 1, the Authority will implement a dedicated, continuous fire watch of the FitzPatrick Control Room.

The Authority does not agree with the NRC staff that this fire watch is necessary to compensate for the lack of redundant fuses on alternate equipment for the following reasons: (1) the Control Room is already occupied 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day by a minimum of four individuals. Three Reactor Operators routinely visit all i- areas in the Control Room as part of their normal tasks. A plant security guard is also continuously.present in the FitzPatrick Control Room. The addition of a fifth individual will not improve the ability to quickly detect and suppress a I

fire. (2) Control Room cabinets are equipped with fire detection devices with audible alarms.

Fire watches will not be performed in either the Relay Room or the Cable Spreading Room because of the area-wide. fire detection and suppression equipment in those areas. In addition, the status of these fire protection systems is displayed in the Control Room.

We may complete additional analysis to further show that the minimum complement of plant operators.can successfully recover from this scenario by manually replacing blown fuses within the allowable time. The Authority will then submit an amended exemption request to eliminate the need for this continuous fire watch, i

-o If you have any question concerning either of these areas, please contact Mr. J. A. Gray, Jr. of my staff.

Very truly yours, J. P yne [

Fi'rst Executive Vice President Chief Operations Officer cc: Office of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, New York 13093 f