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UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION#

BEFORE THE COMMISSION

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In the Matter of |

POWER AUTHORITY OF THE STATE [ Docket No. 50-333*

OF NEW YORK ,

(James A. FitzPatrick Nuclear !*

Power Plant) ,*

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POWER AUTHORITY OF THE STATE OF NEW YORK'SANSWER TO ORDER TO SHOW CAUSE REQUIRINGIMPLEMENTATION OF CATEGORY "A" REQUIREMENTSFOR THE JAMES A. FITZPATRICK NUCLEAR POWERPLANT

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

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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 toadmit 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,~

the Authority respectfully refers the Commission to the

following demonstration:

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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.

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within the 30 days. If this should occur, the installation

1816 215.

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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 andbelieves 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 toSuch instrumentation wasassure core coverage.

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 valveopening and which can give indication of slow leak-

ages through temperature trend analyses.

The Authority's procedures for stuck open relief3.

valves and small break LOCA's can be implemented

without the proposed relief valve indication system.Relief valves in BWR's are frequently used in miti-4.

gating plant transients. The Authority's letter

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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 modifiedto 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.,

1816 277Re,spectfully s,ubmitted

THbShS R. F5E'

General CounselPower Authority of the State ofNew York

10 Columbus CircleJanuary 22, 1980 New York, New York 10019(212) 397-6200

EXHIBIT I

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Babcock & Wilcox %,c~.mc.'

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P.o. Bos 3200. Lynchburg, Va. 24505

Tekvene:(Go4)384-5111

January ll, 1980.

$&cwer Authority State of New York

' 'a L M&10 Colunbus CircleNew York, NY 10019

Subjcct: Valve Monitoring SystemPASNY order no. 19083-79B&W no. 600-5206Delivery Infomation

Attention: Mr. Tom Hannan

Dear Mr. Hannan:'

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

- NEMA-12 cabinet - B&W has ordered NEMA-12 cabinets from Hoffman EngineeringCompany 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 testedand all plans to test equipment in the near future is based on the useof the Hoffman NEMA-12 equipment.

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

- The edgemeters are also long lead items, however, the rneters can beinstalled 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 ~

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J. M. Brunke iojr 37o-

Pr9 duct Manager 80iu ci U

JMB/kjb

The Batcoth & Witox Comyny I rey! het! IBM

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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 ofNew 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 thebest of his knowledge, information and belief.

Dated: January 22, 1980.

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/t 'e '. ;r

PAU /J. EARLYf

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Subscribed and sworn to before me this 22nd day of January 1980.

4d 3Notafy~ Publib g // g

RUTH G. ZAPF-

Notary Public. State of New York

coM[sNNd"ctIe*sSia"rc$b |0}h 2[hNo. 30 4C6M23

My Commission expires:

~b' t-/ |> S o, /YPO

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UNITED STATES OF AMERIC4NUCLEAR REGULATORY COMMISSION

In the Matter of )Power Authority of the )

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

CERTIFICATE OF SERVICE

I hereby certify that copies of the foregoing PowerAuthority of the State of New York's Answer to the Order toShow Cause Regarding Implementation of Category A RequirementsFor The James A. FitzPatrick Nuclear Power Plant have been mailedfirst class, postage prepaid, this 22nd day of January 1980 toeach of the following:

Harold P. Denton, DirectorOffice of Nuclear Reactor RegulationU. S. Nuclear Regulatory CommissionWashington, D. C. 20555 (1) original +

(20) copies

Samuel J. ChilkSecretaryU. S. Nuclear Regulatory CommissionWashington, D. C. 20555 (1) copy

Howard K. Shapar, Esq.Executive Legal DirectorU. S. Nuclear Regulatory CommissionWashington, D. C. 20555 (1) copy

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By M7 ' j~~ '

Angel /u.Mirtin,Esq.Power A thority of theState of New York

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18115 280~