ML20070E383
| ML20070E383 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/10/1982 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| TAC-48973, TAC-52539, TAC-53434, NUDOCS 8212170234 | |
| Download: ML20070E383 (5) | |
Text
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Malling Address
, Alabam] Power Company 600 North 18th Street Post Offica Box 2641 Dirmingham, Alabama 35291 Telephone 205 783-6081 F. L Clayton, Jr.
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tte southern eiwinc system December 10, 1982 Docket No. 50-364 Director of 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 Deletlon Request Gentlemen:
Alabama Power Company submitted a proposed change to the Farley Nuclear Plant - Unit 2 Technical Specifications on October 8, 1982, that requested deletion of the turbine valve testing requirements.
That submittal included a report prepared for Alabama Power Company by Westinghouse, WCAP-10161, justifying the deletion of valve operability testing from the technical specifications.
Recently, Alabama Power Company was informed that i
the NRC review was being delayed because of a September 8,1982 l
letter (CT-24001) from Westinghouse that contained a recommendation j
for weekly turbine valve testing.
Apparently, the NRC Staff j
considered these two documents from Westinghouse to be inconsistent.
Alabama Power Company wishes to clarify this misunderstanding to support our conclusion that the current l
l technical specification requiring weekly turbine valve testing is unjustified as stated in the Alabama Power Company October 8,1982 submittal.
Attached is a copy of the Westinghouse letter that is scheduled to be signed during the week of December 13, 1982.
This letter states that the WCAP-10161 conclusion is valid and is separate and apart from the equipment availability and industrial safety recommendations for weekly turbine valve testing.
Furthermore, Westinghouse states that WCAP-10161 is separate and distinct from any ongoing generic discussion of missile generation 8212170234 821210 b
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Mr. S. A. Yarga December 10, 1982 Director of Nuclear Reactor Regulation Page 2 U. S. Nuclear Regulatory Commission and is a comprehensive evaluation of turbine valve testing applicable to the Farley Nuclear Plant.
Therefore, We-tinghouse supports and defends WCAP-10161 and CT-24001.
It is '.ie opinion of Alabama Power Company that Westinghouse does not havc a rigorous basis for a recommendation on the frequency of valve testing related to plant availability and industrial safety.
Alabama Power Company will determine prudent action to be taken with respect to valve testing as related to plant availability and industrial safety.
Alabama Power Company requests that the NRC review of the October 8, 1982 submittal be expedited since the present turbine valve testing requirement is imposing loss of electric generation capability without concomitant safety benefits.
Since this testing cannot be done while maintaining 100% power, as noted in the attached Westinghouse letter, the economic cost of this testing is unavoidable without the proposed change to the technical specifications requested in the October 8,1982 letter.
Alabama Power Company welcomes any opportunity to work with the NRC to expedite review and resolution of this proposed technical specification change.
Yours very tr y,
8h F. L. Cl ayton, J r.
FLCJr/GGY:jc-D32 Attachment cc:
Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford
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Mr. W. 0.~Whitt Mr. R. P. Mcdonald Mr. H. O. Thrash Mr. O. D. Kingsley, Jr.
Mr. W. G. Hairston, III Mr. J. W. McGowan t
e Mr. C. D. Nesbitt Mr. R. G. Berryhill Mr. D. E. Mansfield Mr. J. A. Ripple Mr. E. A. Worden Mr. W. G. Ware Mr. L. B. Long Mr. J. R. Crane Mr. K. C. Gandhi i
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C"3S Weslinghouse Water Reactor Elecflic Corporation Divisions December 10, 1982 Mr. O. D. Kingsley Manager of Nuclear Engineering and Technical Support Alabama Power Company bE 6206 Flint Ridge Road Flint Ridge Building Fairfield, Alabama 35064
Dear Mr. Kingsley:
JOSEPH M. FARLEY NUCLEAR PLANT UNITS I AND 2 Recommended Turbine Valve Testing Interval Recent Vestinghouse publications issued on.the subject of turbine valve testing have resulted in considerable controversy due to seeming discrepancies in the recommended valve test interval. To assist in resolution of this matter, Westinghouse offers the following discussion concerning WCAP-10161,
" Evaluation of Impact of Reduced Testing of Turbine Valves" and CT-240Dl,
" Functional Testing Requirements for Nuclear Turbines".
1.
CT-24001 contains a generic recomendation for testing turbine valves on a v
weekly basis which is applicable to both fossil and nuclear units, except w
when specifiq qircumstances indicate either more or less frequent testing is justifiedta).
As discussed in k' CAP-10161, valve testing has little demonstrated benefit in identifying equipment failure precu.' sors which lead to ultimate gross valve failure. There are however, potential econo-q.
mic and industrial safety benefits to be gained by frequcnt valve testing, e.g., valve tests could identify sluggish valve action which could result.
7 in outages and reduced equipment and plant availability.
2.
WCAP-10161 was written in view of the impact of frequent valve testing on plant operation, to address licensing issues associated with turbine valve testing at the rarley Nuclear Plant, i.e., the safety implications associ-ated with turbine operation that necessitate a specific licensing require-ment on turbine valve testing as contained in the Farley Nuclear Plant Technical Specifications (b)
The conclusion of the WCAP is that based on past operating history and analytical considerations a specific licens-ing requirement to test turbine valves is unjustified. This conclusion is supported by the maintained high reliability of the turbine valves and turbine trip system and the inprobability of generating a missile without reliance on periodic valve testing.
Based on this study there is just reason to petition for remosal of this requirement from the technical
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specifications allowing the operating utility more flexibility to match s
turbina valve tests with specific system and equipment requirements.
g Y )ent recomendations.#e the opinion of Westinghouse there is no conflict betw p
WCAP-10161 concludes that a specific licensing requirement is unjustified by demonstrating the acceptability of reliance on Mrmal shutdown to satisfy valve testing requirements. CT-24001 on the other hand recommends a weekly test interval to minimi2e losses (revenue, availa-bility, equipment, customer satisfaction) to the operating utility and Westinghouse.
WCAP-10161 does not conclude that periodic testing of turbine valves is of no value but that it does not warrant special requirements imposed by the Rutlear Regulatory Conmission via Technical Specifications.
M conclusion, Westinghouse supports and defends WCAP-10161 and CT-24001 (and O
the subsequent modifications) and is of the opinion that there is no conflict
/ lor is there any inconsistency between these documents. Further, WCAP-10161 is separate and distinct from any ongoing generic discussion of missile gene-fation and is a comprehensive and conservative evaluation of turbine valve i.,
festing at the Farley Nuclear Plant that stands on its own merit.
Sincerely, 5
E. P. Rahe, Jr., llanager e-fluclear Safety Department w
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g DRAFI J. D. Conrad, Jr.
5 Director of Projects Westinghouse STGD
- 1) Westinghouse is currently evaluattag changing this recommendation to e'
monthly in view of more recent studies.
- 5) When turbine governor valve tests are conducted at 100%, a load reduction will occur.
When this reduction must be made in advance of the test because of the condition of or impact on other plant equipment or systems, there may be a substantial increase in the time at reduced power.
(k 0: R. P. ficDonald - APCo J. C. liiller - W HSID O. L. Walters - W STGD g
D. W. Call - W NTD M
R. J. Sitober~- W N1D
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