ML20064G747

Application to Amend Licenses NPF-2 & NPF-8,deleting Requirements for Boron Injection Tank & Boron Injection Heat Tracing

ML20064G747
Person / Time
Site:	Farley
Issue date:	12/30/1982
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20064G750	List: ML20064G747 ML20064G752
References
TAC-49234, TAC-49323, NUDOCS 8301110626
Download: ML20064G747 (4)

Text

MalHng Address Alabama Power Company 600 North 18th Street

• Post Office Box 2641 Dirmingham, Alabama 35291 Telephone 205 783-6081 A F. L Clayton, Jr.

Senior Vice President Flintridge Duildmg M3h3g]3 ggg-tre souttwxn clectrc systern December 30, 1982 Docket Nos. 50-348 50-364 I

Director, Nuclear Reactor Regulation l U. S. Nuclear Regulatory Commission l Washington, D. C. 20555 l Attention: Mr. S. A. Varga i

Joseph M. Farley Nuclear Plant - Units 1 and 2 l Boron Concentration Reduction in the Boron Injection Tank Gentlemen:

Alabama Power Company has completed an evaluation of the costs and benefits of maintaining a highly concentrated solution of boric acid in l the boron injection tanks (BIT) at the Joseph M. Farley Nuclear Plant -

Units 1 and 2. The conclusion of this evaluation is that the boric acid solution in the BIT is not required to mitigate the consequences of FSAR analyzed accidents and in addition represents a significant maintenance and operations cost with no attendant safety, enhancement. As a result, l Alabama Power Company respectfully requests the deletion of the Technical Specifications related to the BIT.

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The original purpose of providing a highly concentrated source of boric acid (i.e., 20,000 ppm) in the BIT was to provide additional margin of safety for the postulated worst case main steam line break (MSLB) accident. Based on a detailed re-evaluation of the Joseph M.

Farley FSAR accident cases for MSLB, reducing the boron concentration in the BIT to O ppm does not result in exceeding any plant safety-related design criteria. The reanalysis concludes that with 0 ppm boric acid in l

the BIT, the worst case MSLB containment peak pressure was 46.1 psig which is significantly below the containment design pressure of 54 psig. Furthermore with the calculated peak temperature of 378 F, Alabama Power Company has determined that there would be no af fect on the environmental qualification of components required for safe shutdown and accident mitigation. A detailed discussion of the calculations, i

results and conclusions is included in Attachments 1 and 2.

The costs associated with maintaining 20,000 ppm boric acid in the BIT include the following:

Continuous maintenance problems associated with the '

gA J necessary heat tracing systems such as heater burnout and frequent low temperature alarms, gd( )($/ksjkW 8301110626 821230 PDR ADOCK 05000348 ' F) ih P PDR

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,o Mr. S. A. Varga December 30, 1982 Director, Nuclear Reactor Regulation Page 2 U. S. Nuclear Regulatory Commission Continuous maintenance problems associated with boron precipitation such as clogged pipes, clogged valves and pump damage.

Significant manpower associated with preparing a solution of 20,000 ppm boric acid to maintain the technical specification limits.

Potential inadvertent safety injection events would result in extending the time required for startup by generating larger volumes of water to be processed due to the introduction of highly concentrated boric acid into the reactor coolant system.

Therefore, the costs of maintaining highly concentrated boric acid in the BIT have significant negative impacts on plant availability and manpower expenditures for maintenance and operation. The benefit of this design feature is marginal and, as discussed above, is not necessary to meet any plant safety-related design criteria.

The proposed changes to the Joseph M. Farley Technical Specifications are contained in Attachment 2 (Section VI). The changes include deleting the requirements on the BIT (Section 3/4.5.4.1) and on the Boron Injection System Heat Tracing (Section 3/4.5.4.2). Ad-ditionally, rewording of the Technical Specification BASES is included in conjunction with these technical changes. ,

Alabama Power Company requests approval of the proposed technical specification changes by March 31, 1983,< to support the planning and scheduling for Unit 1 Cycle 5 restart. If approval is not granted by March 31, 1982, the necessary action to mix the highly concentrated boric acid solution may become a critical path item that could delay the scheduled restart of Unit 1.

Alabama Power Company's Plant Operations Review Committee has reviewed this proposed change to the Technical Specifications and has determined that no unreviewed safety question is involved as shown in Attachment 1. The Nuclear Operations Review Board will review this proposed change at a future meeting.

The class of this proposed change is designated as Class III for Unit 1 and Class I for Unit 2 in accordance with 10 CFR 170.22 requirements. Enclosed is a check for $4,400 to cover the total amount of fees required.

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Mr. S. A. Varga December 30, 1982 [

Director, Nuclear Reactor Regulation Page 3 U. S. Nuclear Regulatory Commission In accordance with 10 CFR 50 30 (c)(1)(i), three. signed originals and forty (40) additional copies of this proposed change are enclosed.

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

FLCJ r/GGY:I sh-D35 SWORN TO AND SUBSCRIBED BEFORE ME Attachments THIS Je 8 DAY OF W L -1982 cc: Mr. R. A. Thomas Mr. G. F. Trowbridge f Mr. J. P. O'Reilly dh4], 8A >m /

Mr. E. A. Reeves

~

totary Public Mr. W. H. Bradford My Commission Ejpires:

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ATTACHMENT 1

. SAFETY EVALUATION FOR FARLEY UNITS 1 AND 2 BORON CONCENTRATION-REDUCTION-IN THE BIT

]

Background:

The BIT is a component of the Boron Injection System, which is part of the Safety Injection System. The purpose of the BIT is to store boric acid solution for injection into the-reactor coolant system upon actuation _af_a safety injection signal. Currently, the BIT .contains 20,000-22,500 ppm boric acid solution, which requires a heat tracing system to prevent the solution from f alling below the solubility . limit and thus precipitating. Alabama Power Company plans to remove the boric acid solution from the BIT. Subsequently, the heat tracing system will no longer be required, and will be deenergized.

References:

(1) Farley - Unit 1 Technical Specifications 3/4.5.4, B3/4.5.4 and B3/4.5.5 (2) Farley - Unit 2 Technical Specifications 3/4.5.4, B3/4.5.4 and B3/4.5.5 (3) Joseph M. Farley Nuclear Plant Final Safety Analysis Report .

(4) Joseph M. Farley Nuclear Plant - Units 1 and 2, Boron Concentration Reduction in the BIT Report (Attachment 2)

Bases:

The attached report entitled " Joseph M. Farley Nuclear Plant - Units 1

, and 2, Boron Concentration Reduction in the BIT" provides the bases for the elimination of the requirements for concentrated boric acid solution in the BIT. The results of the analyses demonstrate that all plant safety design criteria are met when the boric acid solution is removed

, from the BIT. The proposed technical specification revisions are l provided in Section VI of the report.

Conclusion:

The proposed deletion of the requirements for concentrated boric acid 3

solution in the BIT and changes to sections 3/4.5.4, 83/4.5.4 and B3/4.5.5 of the Farley Technical Specifications do not involve an unreviewed safety question as defined by 10 CFR 50.59.

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