ML19344E582
| ML19344E582 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/15/1980 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| IEB-79-02, IEB-79-14, NUDOCS 8009020301 | |
| Download: ML19344E582 (9) | |
Text
7~~<L Alab:ma Power Company, 600 North 18th Streat
- 3 Post Office Box 2641 Birmingham, Alabama 35291
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Telephone 205 250-1000
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- Tf, F. L CLAYTON, JR.
Senior Vice President
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7 Alabama Power the southern electre system August 15, 1980 4)
Docket N Mr. J. P. O'Reilly U. S. Nuclear Regulatory Comission Region II Suite 3100 101 Marietta Street, N.W.
Atlanta, Georgia 30303
Dear Mr.- 0'Reilly:
Attached are revisions of our response to I.E.Bulletin 79-02, Revision 2, Item 9 submitted to your office January 7,1980, and of our response to I.E.Bulletin 79-14, submitted to your office January 15, 1980. These describe a phased completion of our IEB 79-02 and IEB 79-14 activities for Farley Nuclear Plant Unit 2.
Alabama Power Company believes that these programs are scheduled in a manner which will support timely initial plant startup and testing, and provide an adequate margin of safety to the public as described herein.
Very truly yours, i.
A F. L. Clayto Jr.
CLB:de Attachments cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. W. H. Bradford NRC Office of I & E Washington, D. C.
800002030)
s ATTACHMENT 1 Response to Item 9. I.E.Bulletin 79-02 In order to expedite the completion of the 79-02 program for Farley t' nit 2, Alabama Power Company has assigned priorities for testing and repair (if necessary) to concrete expansion anchor bolts installed on piping systems (or portions of piping systems) within the scope of the program. The priorities and their schedule for completion are:
Priority 1 The testing and repair (if necessary) of concrete expansion anchor bolts installed on scoped systems or portions of scoped systems assigned to priority 1 are required to be completed prior to fuel load. The choice of these systems was based on Farley Technical Specification provisions for systems and equipment required to be operable in modes 5 and 6.
- Systems, portions of systems, or equipment and ancillary equipment required to be operational in these modes include:
a.
Refueling water storage tank b.
Charging pumps c.
Baron addition d.
Safety injection e.
Pressurizer relief piping f.
Portions of the CVCS system required for control of reactor coolant system chemistry g.
Fire protection i.
Diesel generators
~
- j. Containment purge k.
Service water as necessary to ensure operability of systens
- a. through k. above m.
Component cooling water as necessary to ensure operability of systems a. through k. above.. -.
I.E.B. 79-02, Item 9 priority 3 will be completed prior to exceeding 5% power. The risks involved in causing an undue radiation dose exposure to the public and plant personnel during this period at power levels of 5% or below are minimal. Bases for adequate safety during the testing period at power levels of 5% or below are as follows:
The period of time associated with operation in this mode is very short (about 6 weeks) and decay heat levels in the reactor core will be low because of the low power levels and short operating history. Further, from current trend data, it is expected that 5% or fewer of the expansion anchor bolts on priority 3 systems will require upgrading.
Alabama Power Company believes this phased schedule for the completion of 79-02, based on the above, ensures the safety of the public during these activities.
Documentation for the program will be maintained on site.
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ATTACHMENT 2 Response to I.E. Bullet'in 79 Farley Unit 2 The final seismic analyses of the as-built configuration of piping
.,3ystems are in process but have not yet been fully cer oleted.
The scope of this program includes all safety related piping 2 inches in diameter and greater and all seismic Category I piping, regardless of size, which was dynamically anal which is connon to both Unit 1 (yzed by computer. The river water system operating) and Unit 2 is excluded since it was addressed under the Unit 179-14 program.
Through field inspection, Alabama Power is producing verified as-built information which will be used as input to the final seismic analyses. The field verified as-built infonnation and other design documents will include the following:
a.
pipe run geometry (length and direction) b.
location on the pipes of the following:
1.
valves 2.
in-line pumps 3.
pipe' hangers 4.
pipe restraints 5.
pipe anchors 6.
welded attachments 7.
floor and wall penetrations 8.
piping welds (ASME Class 1 piping systems only) 9.
any other ir.-line equipment
- 10. branch lines, drains, etc.
c.
valve information 1.
valve identification number 2.
valve configuration 3.
extended operator orientation 4.
valve weight (will be obtained from vendor supplied data).
= -... -.
I.E.B. 79-14 d.
penetration information 1.
penetration identification number 2
piping fixed at the penetration 3.
piping free to move'
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4.
grouted or sealed sleeve m
5.
clearances e.
pipe support information 1.
support identification number 2.
direction (restraint or load carrying direction) 3.
type (spring, snubber, rigid, structure frame) 4.
size, orientation and configuration of members and base plate (s ).
Insulation will be removed where necessary either to inspect welding on ASME Class 1 piping systems or to obtain any other required measurements (e.g., welded attachments). The field verified as-built information will be used to perform seismic analyses. The sample package of design documents for the pressurizer relief line provided in the August 2,1979, response for Unit 1 is representative of the types of design input information being generated by the walkdown.
When a seismic analysis of the verified as-built information identifies an inspection element which is not consistent with analytical requirements (e.g., over-deflection of a hanger resulting in excessive pipe wall stresses),
the designer will issue a change notice specifying the required corrective action. Alabama Power will supply the designer with a new field verified l
as-built after completing the corrective action. This new as-built will be used as a revised input for the seismic analysis.
In order to expedite the completion of the 79-14 program for Farley Unit 2, Alabama Power Company has assigned priorities for the completion of inspection and analysis to hangers and piping systens (or portions of piping systems) within the scope of the program. The priorities and their schedule for completion are:
. l
e I.E.B. 79-14 Priority 1 The inspection and analysis of scoped systems or portions of t
systems assigned to priority 1 are required to be load.
Specification provisions for systems and equipment required to b in modes 5 and 6 Systems, portinns of systems, or equipment required to rable (e operational in these modes include:
Refueling water storage tank a.
b.
Charging pumps c.
Boron addition d.
Safety injection Pressurizer relief piping e.
f.
coolant system chemistryPortions of the CVCS system require g.
Fire protection i.
Diesel generators
- j. Containment purge
.~
k.
Service water as necessary to ensure operability of systems
- a. through k. above Component cooling water as necessary to ensure operability of m.
i systems a. through k. above.
that seismic Category I piping necessary for modes 1
conform to applicable design criteria.
o
_ Priority 2 Remaining scopd systems or portions of scoped systems within the containment building not included in priority 1 are d 2.
i be completed prior to fuel load.
being performed by Bechtel Power Corporation to ensure that significant discrepa repair,1f necessary.ncies are given expedited handling in analysis and The as-built analysis of systems or portions of Bases for ensuring safety is as follows: systems within priority 2 will be r
I.E.B. 79-14 Prior to initial criticality the reactor coolant pumps are the heat source to increase and maintain the primary system coolant temperature at the required values for testing. Due to the fact that nuclear fission process heat is not involved in the pre-criticality test program, no fission products are available that could be released from the plant and provide a dose to the public.
.er Evaluation of the possibility of a re-start accident resulting from a high energy line break has been made. Westinghouse analyses presented in Table 6.1 of "WCAP-9710, The Nuclear Design of the J. M. Farley Unit 2 Power Plant, Cycle 1" indicates that for Beginning of Life, cold conditions (70 F,14.7 psia),
0 with the most reactive rod stuck out of the core, a boron concentration of 1102 ppm will assure 1% shutdown margin with 100 ppm allowance. Therefore, a drop in reactor temperature
. as a result of a high energy line break will not initiate criticality if the boron concentration is maintained above 1102 ppa. Technical specifications require 2000 ppm boron concentration while in Mode 6, Alabama Power Company will initiate controls to ensure that boron concentration will be maintained above 1200 ppm prior to initial criticality.
Priority 3 All remaining scoped systems or portions of scoped systems not included in priority 1 or priority 2 are designated as priority 3'.
The inspection of systems or portions of systems within priority 3 will be completed prior to fuel load. On-site review of the inspection data is being perfonned by Bechtel Power Corporation to insure that potentially significant discrepancies are given expedited handling in analysis and repair,if necessary. The as-built analysis of systems or portions of
. systems within priority 3 will be completed prior to exceeding 5% power.
The risks involved in causing an undue radiation dose exposure to the public and plant personnel during this period are minimal. Bases for adequate safety during the testing period at power levels of 5% or below are as follows:
The period of time associated with operation in this mode is very short (about 6 weeks) and decay heat levels in the reactor core will be low because of the low power levels I
and short operating history.
Further, from current trend data, it is expected that 5% or fewer of the pipe supports on priority 3 systems will require significant modifications.
Alabama Power Company believes this phased schedule for the completion of the 79-14 inspection and analyses, based on the above, ensures the safety of the public during these activities.
Existing FNP Quality Control Procedures during the construction phase provide adequate confidence that any changes in inspection elements.
I.E.B. 79 14 occurring after the field inspection will be documented utilizing a Field Change Request and/or a Non-Conformance Report requiring designer approval.
After rece'et of an operating license for Unit 2 the controls indicated in Attachmcr.t 2 of the October 5,1979, response for Unit 1 will also be applicable for Unit 2.
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