ML20049J349

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Advises That Delay in Replacement of Environmentally Qualified Solenoid Valves (Ref IE Bulletin 79-01B) Will Not Adversely Affect Facility Operation.Mods to Four Fire Dampers Delayed Until Fourth Refueling Outage
ML20049J349
Person / Time
Site: Farley Southern Nuclear icon.png
Issue date: 03/08/1982
From: Clayton F
ALABAMA POWER CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
IEB-79-01B, IEB-79-1B, NUDOCS 8203150149
Download: ML20049J349 (4)


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Malling Address Airbims Powcr Comp:ny 4

600 North 18th Strut b

Post Office Box 2641

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Birmingham, Alabama 35291 Telephone 205 783-6081 b

F. L. Clayton, Jr.

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AlabamaPower J

the southern electnc system March 8, 1982 Docket No. 50-348 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street, N.W.

Atlanta, Georgia 30303 Joseph M. Farley Nuclear Plant - Unit 1 NRC Commitment Compliance Status

Dear Mr. O'Reilly:

In order to provide the latest status of licensing commit-ments related to Farley Unit 1, Alabama Power Company is pro-viding additional information related to the subjects of environmental qualification and fire protection.

The status of these licensing matters is described below.

Environmental Qualification In order to comply with 1.E. Bulintin 79-01B, Environ-mental Qualification of Class IE Equipment, Alabama Power Company committed by letter dated August 25, 1981 to take corrective action on specific components during the third h

refueling outage.

It is now evident that replacement of environmentally qualified solenoid valves will not be l

completed during the third refueling outage.

At the time this commitment was made, the third refueling outage was i

scheduled for March,1982.

Because of unexpected main generator problems, the third refueling outage actually began in September, 1981.

This situation was described to the NRC by letter dated December 28, 1981, " Environmental Qualification of Safety Related Electrical Equipment".

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The December 28, 1981 letter identified that installation l

of two (2) solenoid valves inside containment and 29 i

solenoid valves outside containment as being the only outstanding modifications necessary to satisfy the re-l quirements of I.E. Bulletin 79-01B.

Since that time, RoVV 3

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8203150149 820308 l

PDR ADOCK 05000348 i

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Mr. James P. O'Reilly, Director March 8, 1982 U. S. Nuclear Regulatory Commission Page 2 s

Alabama Power Company has been able to expedite material deliveries and to complete the installation of a portion of the outstanding modifications.

Presently, all installations have been completed except for two (2) solenoid valves inside containment and six (6) solenoid valves outside containment.

This represents less than 2%

I of the total amount of equipment requiring qualification documentation.

Despite efforts to expedite procurement of fully qualified replacement valves located inside containment, current delivery dates will preclude their installation during this outage.

The present scheduled installation of the replacement qualified solenoid valves will be no later than the return to power from the fourth ref ueling outage.

The six (6) remaining solenoid valves located outside containment will be replaced in conjunction with another licensing matter (i.e., auxiliary feedwater modifications).

These changes are scheduled to be implemented at the fourth refueling outage.

Interim operation of the two (2) remaining solenoid valves located inside containment to the fourth refueling outage is justified due to the relatively short required operating time of the solenoid and previous limited testing.

These solenoids would be required to function in approximately 30 seconds and the intrinsic nature of the thermal lag of the solenoid housing would preclude damage to the internal components.

Although complete l

qualification testing or analysis has not been performed on this specific solenoid valve model, separate limited qualification tests have been successfully completed on the individual constituent components of the solenoid.

In the event of harsh environmental conditions resulting from a LOCA or HELB, it is the opinion of Alabama Power Company that the solenoids would complete their intended function prior to adverse ef fects from the harsh environment.

Interim operation of the six (6) remaining solenoid valves located cutside containment to the fourth refueling outage is justified on the basis that the harsh environment is of a short duration and the potential subsequent failure would not prevent the plant from achieving a safe shutdown condition.

In the event of harsh environmental conditions resulting from a HELB, the accident temperature excursion to which the solenoids are exposed is less than two

, Mr. Jases P. O'Railly, Director

. March 8, 1982 U. S. Nuclear Regulatory Cc:aissicn Paga 3 seconds in duration.

The thermal lag of the solenoid housing preclu' des damage to internal components prior to the completion of their intended function.

The potential failure of the solenoid valves after this period would not affect the operation of any other safety related equipment.

The components on which these solenoids are utilized are redundant to equipment capable of completing the intended function.

The redundant equipment is either not exposed to, or unaffected by, the harsh environmental conditions and would not be subject to an environmentally caused common-mode failure.

Current emergency operating procedures and operator training address the utilization of the redundant equipment to achieve the safe shutdown condition.

Based on the above use of these solenoids for one additional fuel cycle does not significantly increase the risk of their failure.

Tnerefore, extending this I.E.

Bulletin 79-01B environmental qualification requirement until the fourth refueling outage will not have a signifi-cant impact on the safe operation of Farley Unit 1.

Fire Protection In response to the NRC Inspection of March 10-13, 1981, Report No. 50-348/81-06, Alabama Power Company committed to the NRC in letter dated May 11, 1981 to inspect the Unit I fire dampers and correct any identified defi-ciencies prior to the return to power from the third refueling outage in order to satisfy the guidelines of Appendix A to Branch Technical Position APCSB 9.5-1,

" Guidelines for Fire Protection for Nuclear Power Plants".

This commitment date was based on the original scheduled third refueling outage date of March, 1982.

Because of the unexpected main generator problems, the third refueling outage actually began in September, 1981.

The inspection has been completed and 238 dampers identified requiring evaluation and/or corrective action.

At the present time, modifications to 211 dampers have been completed with modifications to another 23 dampers scheduled during this outage.

The modifications to the remaining four (4) dampers can not be completed during this outage.

Three (3) of these four (4) remaining dampers can not be modified due to procurement dif ficulties with deliveries af ter the scheduled restart of the unit.

Therefore, the modifications to these three remaining dampers are scheduled for implementation no later than the return to power from the fourth refueling outage.

The modification to the remaining damper is being addressed in another design change (civil modifications of auxiliary building f

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e Mr. James P. O'Reilly, Director March 8, 1982 U. S. Nuclear Regulatory Commission Page 4 rooms) and will be implemented with this modification.

This design change including the damper is planned for implementation prior to the completion of the fourth refueling outage.

If you have any questions concerning these matters, please let us know.

Yours very truly, A

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FfL.Clayton,J(4 FLCJ r/ MAL:j c cc:

Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. E. A. Reeves Mr. ~ J. _ A. lVarga Mr. W. H. Bradford I

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