ML20073C375

Application for Amend to Licenses NPF-2 & NPF-8,revising Tech Specs to Allow Continued Operation & Necessary Compatibility Between Fuel Cycles & Surveillance Intervals

ML20073C375
Person / Time
Site:	Farley
Issue date:	04/05/1983
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20073C378	List: ML20073C375 ML20073C392
References
NUDOCS 8304130127
Download: ML20073C375 (5)

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Malling Address Alltrma Power Company 600 North 16th Street Post Offica Box 2641 Birmingham. Alabama 35291 Telephone 205 783-6081 F. L Clayton, Jr.

22' JeOT4*"' AlabamaPower the sotAhem electnc system April 5,1983 Docket Nos. 50-348 50-364 Di rector, 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 Technical Specification Surveillance Requirements Gentlemen:

Alabama Power Company is currently operating the Joseph M. Farley Nuclear Plant - Units 1 and 2 on standard 12-month fuel cycles. The corresponding technical specification surveillance requirements for refuelirg outage related surveillance are mainly based on 18-month i nte rval s . This interval allows sufficient time for completing surveillance requirements due to the 6-month contingency allowance that is included in the technical specifications.

Alabama Power Company plans to implement 18-month fuel cycles beginning with Cycle 3 at Unit 2 and Cycle 6 at Unit 1. In order to maintai n the 6-month contingency period that currently exists in the technical specifications, the surveillance interval requirements for the 12-month fuel cycles must be extended for the 18-month fuel cycles. The surveillance activities that are performed during a refueling outage consist of those activities that can only be performed when the plant is in a shutdown condition and other activities scheduled for a refueling outage in order to maximize surveillance testing efficiency. As shown in Attachment 1, this change to the technical specifications is justified f rom an operability standpoint and a reliability standpoint.

No exemption or change to the technical requi rements (i .e., setpoi nts, safety limits, etc.) is involved in this proposed technical specification change.

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Mr. S. A. Varga April 5,1983 U. S. Nuclear Regulatory Commission Page 2 The proposed changes to the Joseph M. Farley Technical Specifica-tions are included as Attachment 2. These proposed changes will allow continued operation of the plant and the necessary compatibility between the fuel cycles and surveillance intervals. Additionally, these changes should be considered for other proposed technical specification amend-ments that are currently being evaluated by the NRC.

i Alabama Power Company requests approval of the proposed technical specification changes by October 1,1983, to support the planning and scheduling of surveillance testing for Cycle 3 at Unit 2, the initial 18-month fuel cycle for the Joseph M. Farley Nuclear Plant.

i Alabama Power Company's Plant Operations Review Committee has reviewed this proposed change to the Technical Specifications and has 4

determined that no unreviewed safety question is involwed as shown in Attachment 1. The Nuclear Operations Review Board will review this change at a future meeting.

The class of this proposed change is designed as Class III for Unit

, 1 and Class I for Unit 2 in accordance with 10CFR170.22 requirements.

Enclosed is a check for $4,400 for the total amount of fees required.

In accordance with 10CFR50.30(c)(1)(1), three signed originals and f orty (40) additional copies of this proposed change are enclosed.

You rs ve ry truly, 1

F. L. Clayton, Jrf FLCJ r/GGY: jc-D40 SWORN TO AND SUBSCRIBED BEFORE ME Attachments '

cc: Mr. R. A. Thomas THISJfiks DAY OF , 1983.

Mr. G. F. Trowbridge t 17 i Mr. J. P. O'Reilly GL/ t. 6 Mr. E. A. Reeves Nota ry Public Mr. W. H. Bradford My Commission Expi res:

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ATTACHMENT 1 l

t Safety Evaluation for the Proposed Changes to

The Technical Specification Surveillance Requirements for the i Joseph M. Farley Nuclear Plant - Units 1 and 2 BACKGROUND

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Alabama Power Company 'is currently operating Joseph M. Farley Nuclear i Plant - Units 1 and 2 on 12-month fuel cycles. The technical specifi-  ;

cation surveillance requirements for the 12-month . fuel cycles are based l on 18-month intervals which include a 6-month contingency period to ,

perform outage related surveillance. The surveillance activities that l are performed during a refueling outage consist of those activities that ,

can -only be performed when the plant is in a shutdown condition and -  !

other activities . scheduled for a refueling outage in order to maximize [

surveillance testing efficiency. The 6-month contingency period is 4 extremely important because it includes an allowance for time lost due j to unscheduled or forced outages during normal cycle operation, which in -

turn permits the required surveillance to be performed without imple- [

menting surveillance extension provisions, requiring emergency technical i specification relief, or requiring plant shutdown. Commencing with the -j

) Unit 2 Cycle 3 and Unit 1 Cycle 6 fuel reloads, Alabama Power Company 1 plans to implement 18-month fuel cycles. Thus, Alabama Power. Company i proposes to amend the technical specification surveillance requirements l in order to maintain the same contingency period for 18-month fuel -

cycles that currently exists for the 12-month fuel cycles.

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REFERENCES:

1 i j (1) Joseph M. Farley Nuclear Plant - Unit 1 Technical Specifications j (2) Joseph M. Farley Nuclear Plant - Unit 2 Technical Specifications  !

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! BASES:

Two principal considerations are involved in this proposed technical

specification change. These considerations are

(1) the 6-month contingency period for completing the technical specification surveil-  !

! lance requi rements, and (2) ~the potential impact on equipment rel i a-  !

i bility associated with the extension of the surveillance interval.

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The first principal consideration in this proposed technical'specifica-

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tion change is the 6-month contingency period for completing the l su rveillance ; requi reme nts. The current surveillance requirements that exist in the, technical specifications are to be ' performed within the t specified time interval with the maximum' allowable extension not to

• exceed -25% of the surveillance interval, and the combined time interval

! - for any three consecutive surveillance intervals not to exceed 3.25

- times 1the specified time interval. . Si nce' the 12-month fuel cycles have 18-month surveillance ~ intervals, a 6-month contingency period exists to l

Attachment 1 Page 2 l

l perform the required surveillance without implementing the surveillance i extension provisions listed above. Considering that this 6-month period l exists to perform all requi red refueling outage related surveillance.

l the extension conditions are reasonable. However, when the fuel cycles i

are extended to 18 months, the 6-month contingency period is completely eliminated; and the extension provisions become the only allowance available for completing required surveillance activities without' imposing a limiting condition of operation (LCO). Thus, operation in accordance with these requirements becomes excessively restrictive. The 6-month contingency period is necessary for proper operation of the i plant. Without this operational margin, Alabama Power Company would i

inevitably be forced to meet the surveillance requirements by one or more of the following:

l (1) Implementing the 3.25 extension provision. -

(2) Requesting an emergency technical specification change based on impending plant shutdown for the sole purpose of complying with surveillance requirements, or (3) Shutting down the plant for the sole purpose of surveillance.

It is Alabama Power Company's understanding that such a shutdown is contrary to NRC policy.

Alabama Power Company considers the above alternatives to be excessively restrictive and undesi rable. A 6-month contingency period for com-pleting surveillance exists now and has proven to be adequate for the cu rrent 12-month fuei cycles. Likewise, a 6-month contingency period should continue to exist when the fuel cycle is converted to 18 months.

The second principal consideration for this technical specification l change is the potential impact on equipment reliability due to the i extension of the surveillance interval. Plant operational experience at i the Joseph M. Farley Nuclear Plant for equipment associated with this I technical specification change has demonstrated that the equipment is

( highly reliable. For example, instrumentation channel checks and

channel functional tests are performed weekly and monthly on much of I this equipment. Plant records of these checks and tests have l demonstrated the reliability of these instruments. Although l surveillance testing during shutdown has shown instrumentation drift to be present, recalibration of this instrumentation has demonstrated that the drif t is not significant and that drift during the extended surveillance intervals would remain within acceptable limits.

Additionally, the lack of significant irregularities in all equipment-related surveillance testing indicates the dependability of nuclear grade components. Consequently, extension of -the surveillance interval f rom 18 months to 24 months will not result in a significant decrease in equipment reli abi lity .

l l Thus, Alabma Power Company proposes that the 18-month technical specifi-

! cation surveillance intervals be amended to 24-month intervals and l 12-month intervals be amended to 18-month intervals. The proposed technical specification changes are provided as Attachment 2.

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Attachment 1 Page 3 3

CONCLUSIONS:

The proposed amendments to the Farley Technical Specifications - Units 1 and 2 do not involve an unreviewed safety question as defined by i 10CFR50.59. - Additionally, the changes will not af fect the safe opera-tion of either Unit 1 or Unit 2 of the Joseph M. Farley Nuclear Plant.

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