ML20023D880
| ML20023D880 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/31/1983 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| TAC-48973, TAC-52539, TAC-53434, NUDOCS 8306060115 | |
| Download: ML20023D880 (5) | |
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- Mailing Address Alabima Power Company 600 North 18th Street Post Offica Box 2641 Birmingham. Alabama 35291 Telephone 205 783-6081 F. L Clayton, Jr.
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AlabamaPower the southern electic system May 31, 1983 Docket No. 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Unit 2 Turbine Valve Technical Specification Deletion Request Gentlemen:
Alabama Power Company cubmitted a proposed change to the Farley Nuclear Plant - Unit 2 Technical Specifications on October 8,1982, requesting deletion of the turbine valve testing requirements.
The NRC letter of December 30, 1982, concluded that approximately one year would be required to review the generic issue of turbine missiles and that the Alabama Power Company proposal was being included in that generic review.
Alabama Power Company letter dated January 18, 1983, appealed the December 30, 1982 decision and a meeting was subsequently arranged on March 23, 1983.
The NRC letter of April 29, 1983, concluded that, based on the March 23, 1983 meeting, there is no basis for deleting the turbine valve testing requirements on Unit 2.
However, an alternative was proposed to increase the weekly testing requirement to monthly.
Alabama Power Company hereby appeals the NRC decision stated in the April 29, 1983 letter.
The stated bases for the NRC conclusion are not f actually based and are contrary to the material provided by Alabama Power Company and Westinghouse.
The NRC reviews documented in the December 30, 1982 letter and the April 29, 1983 letter either did not consider the information provided in the October 8,1982 Alabama Power Company letter (i.e., WCAP-10161), or the review was not in suf ficient detail to allow a technically justified decision.
This statement is based on the fact that no rebuttal or technical contradiction to the content of WCAP-10161 has ever been provided by the NRC to Alabama Power Company or Westinghouse.
Furthermore, as evidenced by the f act that Farley Nuclear Plant - Unit 1 has no turbine valve technical specifi-cation testing requirements, the existing Unit 2 Technical Specification is not a generic requirement and the NRC decision to delay final revi ew 8306060115 930531 DRADOCK05000g g[
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Mr. S. A. Varga May 31, 1983 U. S. Nuclear Regulatory Commission Page 2 of the Alabama Power Company submittal for Unit 2 pending review of a generic issue is inappropriate.
The October 8, 1982 submittal was based on analysis of the Farley Nuclear Plant and is not generic to other plants.
In response to some of the stated bases for the NRC conclusion in the April 29, 1983 letter, Alabama Power Company has the following comments:
1.
NRC Basis:
" Westinghouse preserted preliminary results of an ongoing study on the generation of turbine missiles being conducted on behalf of some licensees and applicants.
This study specifically includes consideration of the testing requirements for the turbine overspeed protection valves and turbine valve arrangement installed at Farley Unit 2.
The results of this study are not final.
Preliminary indications are that turbine j
valve operability and reliability will not be significantly j
affected by increasing the periodic valve testing f rom the present weekly to a much longer interval."
Comment:
The above discussion in the NRC letter of April 29, 1983, and the conclusion in that letter, completely ignores WCAP-10161 supplied to the NRC on October 8,1982, by Alabama Power Comp a ny.
This WCAP documents final results of a study by Westinghouse regarding the Farley Nuclear Plant - Unit 2 turbine The overspeed protection valves and turbine valve arrangement.
final conclusion of WCAP-10161 was that periodic valve testing is not justified based on turbine valve operability and i
reliability considerations.
WCAP-10161 further documents that turbine missile analysis will not be significantly affected by i
deletion of the technical specification testing requirements.
1 2.
NRC Basis:
i "However, in Westinghouse's judgement, lack of a significant number of valve f ailures, good operating experience, and a well planned maintenance and inspection program provide reasonable bases to increase the periodic test interval for turbines with valve arrangements as installed at Farley Unit 2 from weekly to l
i monthly.
Westinghouse stated that they intend to make a formal recommendation to their customers who have turbines employing turbine valves and steam chest arrangements as installed at i
Farley Unit 2, to change f rom periodic weekly to monthly valve testing."
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Mr. S. A. Varga May 31, 1983 U. S. Nuclear Regulatory Commission Page 3 Comment:
As documented in Alabama Power Company letter of December 10, 1982, Westinghouse specifically separates the recommendation for monthly valve testing f rom the issues of missile generation and nuclear safety.
Westinghouse stated at the March 23, 1983 meeting that the weekly valve testing recommendation was based on equipment availability and industrial safety, not on nuclear plant safety issues.
It was also stated at the meeting that the weekly recommendation had been modified to monthly based on the inf requency of valve problems experienced for units which were conducting weekly testing.
It was emphasized that this change was intuitive and not based on reliability analysis.
The monthly recommendation was prompted in large part by Alabama Power Company's request to evaluate valve failures and their relation to testing f requency.
It appears, as evidenced by the NRC letter of April 29, 1983, that the NRC has placed more emphasis on the intuitive recommendation for monthly testing than the detailed reliability analysis of WCAP-10161 for the Farley Nuclear Plant.
The Alabama Power Company submittal to delete turbine valve technical specification testing requirements is supported and defended by Westinghouse as e%
documented in the October 8,1982 letter; the December 10, 1982 letter; the January 18, 1983 letter; and the presentations made by Westinghouse on March 23, 1983.
3.
NRC Basis:
"Our current position, as stated in SRP Section 10.2, ' Steam Turbines,' requires weekly testing of these valves.
This requirement results from extensive discussions with major steam turbine manuf acturers and is based largely on engineering judgement and the recommendations of these manuf acturers."
Comment:
Alabama Power Company has removed the need to rely on intuitive engineering judgement to establish turbine valve testing at the Farley Nuclear Plant - Unit 2.
The analytical evaluation provided in WCAP-10161 justifies, on a technical basis, the safe operation of Unit 2 with turbine valve testing done on a refueling outage f requency rather than weekly or monthly.
Additionally, the steam turbi ne manuf acturer, Westinghouse, provided the subject analytical evaluation and defeads the elimination of the turbine valve technical specification testing requirement for Unit 2.
Therefore, the basis and conclusion of SRP Section 10.2 are unfounded and unjustified for the Farley Nuclear Plant.
Mr. S. A. Varga May 31, 1983 U. S. Nuclear Regulatory Commission Page 4 4
NRC Basis:
"APCo believes their turbine valve testing, maintenance, and inspection program, carried out at unspecified intervals, is sufficient to provide assurance of valve operation on demand."
Comment:
The NRC statement that the turbine valve testing, maintenance and inspection are carried out at unspecified intervals is not factually based.
The October 8,1982 Alabama Power Company letter documented that a comprehensive inspection and maintenance program for turbine valves, recommended by the turbine - generator manuf acturer, would be continued independently of the technical specification requirements.
At the March 23, 1983 meeting, Alabama Power Company identified the specific intervals for valve maintenance and informed the NRC that calibration and testing of the overspeed protection instrumentation would continue to be performed at refueling outage intervals.
The Alabama Power Company programs for testing, maintenance, inspection and calibration are carried out at specific intervals that have been identified to the NRC and are more frequent than currently required by Technical Specification 3/4.3.4.
It is noted that this commitment will be maintained even considering the new 18 month fuel cycle.
This program is based on the manufacturer's recommendation, resulting in a comprehensive program in excess of any current NRC requirements or guidelines and will be continued on this frequency regardless of the outcome of this pending change to the technical specifications.
In conclusion, Alabama Power Company hereby appeals the NRC decision provided in the April 29, 1983 letter.
Additionally, due to the delays already experienced, it is requested that interim relief from Technical Specification 3/4.3.4 be granted on the basis that Unit 2 is being subjected to unnecessary transients and a loss of electric generation capacity without demonstrated safety benefits.
Unit 1, which is adjacent and essentially identical to Unit 2, does not have a technical specification testing requirement for the turbine valves.
Since turbine valve testing is not an NRC generic requirement and the present technical specification requirement is without documentcd analytical basis, further delay on the basis of NRC review of a generic issue is u nwa rra nt ed.
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Mr. S. A. Varga May 31, 1983 U. S. Nuclear Regulatory Commission Page 5 Alabama Power Company welcomes any opportunity to work with the NRC i
to expedite review and resolution of this proposed technical specification change.
This offer is provided in an effort to foreclose pursuit of other options for appeal by Alabama Power Company, such as higher level NRC appeal and/or legal actions.
t Yours very truly,
. Clayto, Jr. f F LCJ r/GGY : l s h-D19 l
cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford 1
Dr. I. L. Myers i
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