ML20003A897
| ML20003A897 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/02/1981 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8102100021 | |
| Download: ML20003A897 (2) | |
Text
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Alabama Power Company 600 Nortn 18tn street Post Office Box 2641 Birmingham. Alabama 35291 Teleonone 205 250-1000 F. L CLAYTON, JR.
senior Vice President Alabama Power the southem eectrc system February 2, 1981 Docket Number 50-348 Docket Number 50-364 Director, Nuc' ear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
This letter is to request exemption for Farley Nuclear Plant Units 1 and 2 from the requirement of 10 CFR 50 Appendix J, paragraph III.D.2(b)
(ii) which states:
Air locks opened during periods when containment integrity is not required by the plant's Technical Specifications shall be tested at the end of such periods at not less than P *a The basis for this exemption request is that air lock integrity)is adequately assured by the provisions of paragraphs III.D.2(b)(i and III.D.2(b)(iii) and that the requirement of paragraph III.D.2(b)(ii) is excessively restrictive in that it is anticipated to result in one or ' ore days of additional outage time per year on each unit.
WhenevertheplantisinMode5,ContainmentIntegftyisnotre-quired. Hence, if an air lock (Personnel or Auxiliary; is opened in Mode 5, paragraph III.D.2(b)(ii) requires that an overall air lock leak-age test at not less than P be conductM prior to entry into Mode 4.
a Even if the six month test required by paragraph III.D.2(b)(i) is current, to meet the requirement of paragraph III.D.2(b)(ii) no access to the containment can be allowed while preparing to leave Mode 5 until any air lock that has been opened in Mode 5 is tested and the plant has entered Mode 4.
To perform this test requires approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> on the personnel air lock and 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> on the auxiliary air lock. Usually there are several minor operational and maintenance problems that require containment entry prior to entering Mode 4 and the air lock test would have to wait until all problems requiring containment entry were correct-ed. This is very restrictive and would slow return tn operation by at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and in most instances longer, kol)
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810elonogg
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Director, NRR February 2,1981 Page Two If the six month test of paragra required by paragraph III.D.2(b)(iii)ph III.D.2(b)(i) and the test are current and no maintenance has been performed on the airlock, there is no reason to expect the airlock to leak just because it has been opened in Mode 5 or Mode 6.
Thus this additional testing and resulting delay in returning the unit to operation does not seem merited and Alabama Power Company respect-fully requests relief from paragraph III.D.2(b)(ii) of 10CFR50 Appen-dix J.
If you have any questions, please advise.
Very truly yours,
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F. L. Clayton, Jr.
FLCJr/HRF:nac cc: Mr. R. A. Thomas Mr. G. F. Trowbridga Mr. J. P. O'Reilly Mr. L. L. Kintner Mr. E. A. Reeves Mr. W. H. Bradford i
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