ML20062G522

Application to Amend Licenses NPF-2 & NPF-8,incorporating Unit 1 Tech Spec Acceptance Criteria for Leak Testing Reactor Coolant Sys Isolation Valves Into Unit 2 Tech Spec & Deleting Paragraph 4.4.7.3.2 from Both Units Tech Specs

ML20062G522
Person / Time
Site:	Farley
Issue date:	08/10/1982
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20062G525	List: ML20062G522 ML20062G527
References
NUDOCS 8208130061
Download: ML20062G522 (5)

Text

. 5 M;iling Addrxs Alabama Power Company

. 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6081 F. L. Clayton, Jr.

%%;'fa t4*"' AlabamaPower the Southern eleClf tC SYStern August 10, 1982 MPF - 2.

NPF-8 Docket Nos. 50-348 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 - Units 1 and 2 Pressure Isolation Valve Technical Specification Change Requests l Gentlemen:

In accordance with Technical Specifications 4.4.7.3 and 4.4.7.2.2 for Units 1 and 2, respectively, Alabama Power Company is required to perform leak tests of all reactor coolant system pressure isolation valves to assess their operability. The Unit 2 leak test acceptance criteria of 1 gpm versus the Unit 1 criteria of 1 to 5 gpm (with certain limitations) has proven to be excessively restrictive without providing increased assurance of valve operability while resulting in greater radiation exposure to plant personnel and needlessly jeopardizing the timely return of the plant to power operation. In conjunction with this Technical Specification change request, it is determined that Paragraph 4.4.7.3.2 is superceded by the ACTION statement of 3/4.4.7.2 of both Units 1 and 2 and is thereby unnecessary.

Therefore, Alabama Power Company respectfully requests that the Unit 1 Technical Specification acceptance criteria for the leak testing of reactor coolant system isolation valves be incorporated into the Unit 2 Technical Specification and that Paragraph 4.4.7.3.2 be deleted from both Units 1 and 2 Technical Specifications.

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Mr. S. A. Varga August 10, 1982 Director, Nuclear Reactor Regulation Page 2 Acceptance Criteria of Leak Test for Unit 2 The objective of leak testing of the. reactor coolant system pressure isolation valves is to detect valve degradation that could lead to valve failure and a potential intersystem LOCA. The Unit I leak test acceptance criteria of 1 to 5 gpm, under certain limitations defined in the Technical Specifications, are adequate to establish the pressure retaining capability of the valve. As shown by testing experience at Farley Nuclear Plant, valves that did not satisfy either the 1 gpm or the 1 to 5 gpm acceptance criteria were found to contain the same minor valve seating irregularities causing the valves not to seat completely at low pressures.

The minor valve seating irregularities associated with both acceptance criteria are attributed to the tests being performed at less than full operating pressure. Testing at this pressure produces conservative test results since the valves tend to seat fully and leakage decreases as the pressure increases to operating pressure. No evidence of impendin6 valve failure was found using either acceptance criteria during the leak test.

> Moreover, the maintenance work and retesting required to satisfy the more restrictive acceptance criteria of Unit 2 results in greater radiation exposure to plant personnel and needlessly jeopardizes the timely return to power operation. Considering the past Unit 1 outages as examples, six valves repaired out of a total of sixteen tested to the 1 gpm criteria reselted in plant parsonnel receiving approximately 10 times the radiation exposure as that associated with the testing to the 1 to 5 gpm criteria having no valve repairs, i.e., 25.0 rem versus 2.5 rem. Additionally, the duration of the maintenance work and retesting of valves having leak test results that fail to satisfy the 1 gpm criteria could necessitate the drain down of the reactor coolant system and would significantly impact the critical path of the Unit 2 return to power operation.

Consequently, Alabama Power Company proposes to implement the equivalent Unit 1 Technical Specification requirements to the Unit 2 Technical Specification by adding a new Section 3/4.4.7.3 (Attachment 1).

Unnecessary Paragraph for Units 1 and 2 In conjunction with the aforementioned proposed change request, an additional change to the Technical Specifications of both Units 1 and 2 is requested. Specifically, Paragraph 4.4.7.3.2 is superceded and made unnecessary by ACTION statement 3/4.4.7.3 which adequately addresses valve integrity.

Mr. S. A. Varga August 10, 1982 Director, Nuclear Reactor Regulation Page 3 Paragraph 4.4.7.3.2 requires that "whenever integrity of a pressure isolation valve... cannot be demonstrated, the integrity of the remaining valve in each high pressure line having a leaking valve shall be determined and recorded daily." The requirement of Paragraph 4.4.7.3.E to daily monitor the leakage of downstream valves in the system is inappropriate since the ACTION statement requires valve and/or system integrity to be maintained / isolated or the plant is to initiate an orderly shutdown within one hour. Furthermore, such valve leakage monitoring could not be performed while the reactor is in operation or while the reactor coolant system is pressurized due to personnel safety considerations.

Therefore, the ACTION Statement provides the n.ost conservative guidance, and the deletion of Paragraph 4.4.7.3.2 does not affect the safe operation of Unit 1. This proposed paragraph has not been included in the aforementioned requested change to Section 3/4.4.7.3 of the Unit 2 Technical Specifications (Attachment 1).

Conclusion In conclusion, the proposed changes to Technical Specifications 3/4.4.7.2 and 3/4.4.7.3 for Unit 2 and Technical Specification 3/4.4.7.3 for Unit 1 are requested to provide for the highest assurance of reactor coolant system integrity through surveillance and testing requirements without unwarranted compromise to the health and safety of plant personnel and needless jeopardizing of the timely return of the plant to power operation.

The Plant Operations Review Committee of Alabama Power Company has reviewed these proposed changes to the Technical Specifications and has determined that the changes do not involve an unreviewed safety question as shown in the attached safety evaluation (Attachment 2). The Nuclear Operations Review Board is scheduled to review these changes at the next meeting.

Your response to the proposed Technical Specifications changes is respectfully requested by September 21, 1982 in order to provide for their incorporation into the plant procedures prior to the upcoming scheduled refueling outages.

This proposed amendment is designated as Class III for Unit 2 and Class I for Unit 1 in accordance with 10CFR170.22 requirements. Enclosed is a check for $4,400.00 to cover the total amount of fees required.

Mr. S. A. Varga August 10, 1982 '

Director, Nuclear Reactor Regulation Page 4 4

In accordance with 10CFR50.30 (c)(1)(1), three signed originals and forty (40) additional copies of the proposed changes are enclosed.

Yours very truly, F. L. Clayton, r.

FLCJ r/ MAL:lsh-D23 cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford SWORN TO AND SUBSCRIBED BEFORE ME THIS /o d DAY OF as/, 1982.

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