ML19331D913

Submits Response to NRC Request Resulting from 800821-28 Meeting Re App a Tech Specs 3.3.3.8, Accident Monitoring Instrumentation & 3.7.9, Snubbers. Info Should Be Considered in Development of Final App a Tech Specs

ML19331D913
Person / Time
Site:	Farley
Issue date:	09/02/1980
From:	Clayton F ALABAMA POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML19331D914	List: ML19331D913 ML19331D917
References
NUDOCS 8009040246
Download: ML19331D913 (5)

Text

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Alabama Power Company 600 North 18th street Post Office Box 2641 Birmingham. Alabama 35291 Telephone 205 25010m)

F. L CLAYTON, JR.

L senior Vice Pres, dent Alabama Power tre southem erec:nc sys:em September 2,1980 Docket No. 50-364 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. A. Schwencer JOSEPH M. FARLEY NUCLEAR PLANT - UNIT 2 TECHNICAL SPECIFICATIONS Gentlemen:

As a result of meetings with the NRC Staff on August 21-28, 1980, regarding the Appendix "A" Technical Specifications, the Staff stated that Alabama Power Company should formally dccket our requests regarding Specifications 3.3.3.8 " Accident Monitoring Instrumentation" and 3.7.9

" Snubbers". A discussion of these requests are provided below.

Included in Specification 3.7.9 are ACTION statsuents and SURVEILLANCE REQUIREMENTS associated with mechanical type snubbers.

Field testing equipment necessary to comply with the SURVEILLANCE REQUIREMENTS for mechanical snubbers are not currently available but are under development. In light of the above, Alabama Power Company requests an exemption from the mechanical snubber surveillance require-ments until startup following the first refueling outage. The list of mechanical snubbers that should be included in the Technical Specifi-cations will be provided at that time.

The existing ACTION statement for inoperable accident monitoring instrumentation (Technical Specification 3.3.3.8) requires that:

(1) With the number of OPERABLE channels less than the required channels shown in Table 3.3-11 (Attach-ment 2), the inoperable channel must be restored to OPERABLE status within seven days or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

(2) With the number of OPERABLE channels less than the minimum channels shown in Table 3.3-11, the inoperable channels must be restored to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or t 3 in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, l

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Joseph M. Farley Nuclear Plant - Unit 2 -

Technical Specifications

September 2,1980 Page 2 4

Nine of the thirteen accident monitoring instruments identified in Technical Specification 3.3.3.8 Table 3.3-11 for post accident mcnitoring i

have sensors which are located inside containment. Most of the electronic portion of the systems are located outside containment and are accessible for repair during power operation. The operator has backup main control board instrumentation (Attachment 1) that would be utilized for monitoring.

i This backup instrumentation would provide equivalent information to the

, operator during the period of accident monitoring instrumentation in-operability.

The limiting case to return an inoperable channel to operable status would be to replace a transmitter with a sealed reference leg located

, inside containment. To replace a transmitter, the isolation valves (located inside containment) separating the transmitter from the process system must be closed. If these valves do not leak, the replacement can be completed in MODE 3 or 4. If any valve leakage exist, plant cooldown to MODE 5 is required to replace the transmitter. The trans-mitter must be cut out, a valve installed to draw a vacuum, a vacuum drawn on the reference leg for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the replacement transmitter  ;

installed (a qualified welder is required for welding), the reference leg filled and sealed, and the new transmitter calibrated. A trans-mitter replacement time of 3 to 4 days is required after the plant is in the required conditions. In addition to the repair time about seven days is required to shutdown, cooldown the primary system, adjust pri-mary chemistry within limits and perform the necessary surveillance I

testing for startup. Due to the availability of a remaining channel 4 and backup instrumentation, and the possible time required to replace 4

a transmitter, a 31 day ACTION statement is necessary to lessen the impact of plant shutdown _ on the system load.

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If one less than the minimum channels is available for accident monitoring, backup instrumentation (Attachment 1) would be utilized by the operator for monitoring. To' return the inoperable channel to service may require a plant shutdown to repair. Two days to return the inoperable channel to service would be sufficient if the trans-mitter isolation valves did not leak or if the problem was electronic in nature. Seven days would be required to schedule the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> shut-1 down during the weekend minimum load period.

Alabama Power Company request an ACTION statement requiring 31 4

days to restore an inoperable channel to OPERABLE status when less

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than the required accident monitoring channels are_0PERABLE. If less than the minimum accident monitoring channels are operable, an ACTION

, statement requiring seven days to restore the inoperable channels to OPERABLE status is requested. Attachment 2 is a proposed technical

specification for Accident Monitoring Instrumentation.

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Joseph M. Farley Nuclear Plant - Unit 2 -

Technical Specifications September 2, 1980 Page 3 In conclusion, Alabama Power Company requests the NRC Staff consider the above in development of the final " Appendix A" Technical Specifications for Farley Unit 2.

Very truly rs, b "

F. L. Clayton, Jr.

BDM/rt '

Attachments 4

cc: Mr. R. . A. Thomas Mr. G. F. Trowbridge

. Mr. L. L. Kintner Mr. W. H. Bradford l

Mr. D. Vito 1

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bc: Mr. R. P. Mcdonald '

Mr. H. O. Thrash Mr. O. D. Kinglsey, Jr.

Mr. W. G. Hairston, III Mr. K. W. McCracken Mr. O. Batum -

Mr. B. J. George Mr. A. A. Vizzi

ATTACHMENT 1 Accident Monitoring Backup Instruments Instrument

• 1. RCS Temperature Pressurizer temp & pressure; T - Wide Range incore thermocouples; narrow hot range temperature indication at power.

• 2. RCS Temoerature Incore thermocouples; Tcold - Wide Range narrow range temperature indication at power.

• 3. RCS Wide Range Pressurizer pressure Pressure

• 4. Steam Generator Level AFW flow; three narrow range Wide Range / Narrow Range and one wide range channel.

5. Refueling Water Storage RWST level switches that provide Tank (RWST) level MCB alarms; local indication.

• 6. Containment Pressure Four channels narrow range; two channels wide range; phase A, phase B ip status lights.

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• 7. Pressurizer Level Three channels; containment sump level; PRT Level; VCT Level; high energy line break indication.

8. Steam line pressure Feedline pressure; steam flow; local indication; protection grade transmitters; non-safety grade transmitters for control systems.

9. Auxiliary Feedwater (AFW) Steam generator level; AFW motor Flow current; AFW suction flow

• 10. RCS Subcooling Monitor RCS wide range T T RCS wide range press k (68bd51 method to determine sub-cooling).

• 11. PORY Position Indication PRT Level, temperature, pressure; PORV relief line temperature.

• 12. PORY Block Valve PRT Level, temperature, pressure; Position Indication PORV block valve relief line temperature.

• 13. Safety Valve Position PRT Level, temperature pressure; Indication safety relief line temperature indication.

• Sensors located in containment and require shutdown to replace this portion of the system.

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