ML20079R632
| ML20079R632 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/20/1983 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8306240040 | |
| Download: ML20079R632 (6) | |
Text
e
-e g m Alabama Power Company 600 North 18th Street Post Offic) Box 2641 Crmmgham Alabama 35291 Telephone 205 783-6081 F. L Clayton, Jr.
Senior Vice President ggg gp Flintridge Building Ite southern ekctre system June 20, 1983 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 Licensing Items Gentlemen:
On January 4,1983 Alabama Power Company submitted a list of identified licensing items for NRC review and approval in 1983.
Each of these items were identified as critical items to either the operation or license compliance of the Farley Nuclear Plant and it was requested that their approval not be delayed unless mandated by other licensing issues subsequent to the January 4,1983 letter.
These items were also discussed with Mr. E. A. Reeves, the Farley Nuclear Plant NRC Project Manager, during a meeting at the Farley Nuclear Plant in December 1982.
In addition, Alabama Power Company has submitted monthly updates to the NRC for these identified licensing items since that initial submittal.
During telephone conversations in May 1983, the NRC Staff indicated to Alabama Power Company that previous requested approval schedules for some licensing items may not be met.
The specific reasons given for the possible delay are the new requirements in 10 CFR 50.91/10 CFR 50.92 requirements dated April 6, 1983 and the DS-416 reactor trip breaker issue.
In the June update of identified licensing items for NRC review in 1983, Alabama Power Company emphasized the f act that, if approval of several of these items were appreciably delayed, the Unit 2 second I
8306240040 830620 7;
DR ADDCK 050003g8 f
Mr. S. A. Varga June 20, 1983 U. S. Nuclear Regulatory Commission Page 2 refueling outage could be adversely affected or a special outage could be required solely for the purpose of surveillance testing.
Alabama Power Company requests that the specific license amendments discussed herein be given priority such that the reluested review schedules are met.
The referenced licensing items are discussed as follows:
- 1. River Water System Technical Specification Change This proposed change to delete the river water system from the Farley Technical Specifications was submitted to the NRC on December 30, 1982.
NRC approval was requested for July 1,1983 as documented in Alabama Power Company's letter of January 4,1983.
It was anticipated that deletion of the river water system from the technical specification would obviate the need to submit a technical specification change to allow surveillance testing during power operation versus dual unit shutdown as required by currently written technical specifications.
The surveillance testing included in Section 4.7.5.b requires that buried piping be verified to be leak tight and that automatic valves actuate to the correct position on a low pond level signal.
Such testing is not affected by operational mode.
The requested approval date of July 1,1983 was based on the concern that a plant shutdown will be required in August 1983 if NRC approval is not granted.
The one month interval between July and August was needed for planning and scheduling purposes.
Based on subsequent discussions with the NRC Staff, Alabama Power Company will submit an administrative technical specification change by June 27, 1983 to allow surveillance testing at power rather than during plant shutdown if deletion of the total river water system is not provided by August 3, 1983
- 2. RCS Pressure Isolation Valves Technical Specification Changes This proposed change to modify the testing provision of the RCS pressure isolation valves was submitted to the NRC on August 10, 1982.
The requested date for NRC approval was July 1,1983 based upon the need to revise surveillance procedures for the Unit 2 refueling outage currently scheduled to begin early in September 1983 in order that a two month interval be available for procedure revision, planning and scheduling of the surveillance activities.
Based on the potential extension of the refueling period if NRC approval is not given prior to the outage, Alabama Power Company requests that NRC review be completed no later than August 15, 1983.
~_ -
~
l
'Mr.
S'. A. Varga June 20, 1983'
~
i U. S.- Nuclear Regulatory Commission Page 3
{
3.
Unit 2 Inservice Inspection and ~ Inservice Testing Several Inservice. Inspection (ISI) submittals were made concerning relief requests for Unit 2 on July 25, 1980; January 10, 1983; and January 28, 1983 The requestej NRC. approval date was September 1, 1983.
Since the Unit 2 refueling outage schedule has been advanced from October to early. September 1983, NRC approval by September 1, 1983 is now imperative.
If NRC approval is not obtained by September 1,1983, Alabama Power Company would be in violation of the code for certain hydrostatic test requirements and other impractical examinations whica cannot be performed as described in 1
1 the referenced Alabama Power Company submitttals.
In addition, manual examinations would be required for the reactor vessel closure head cladding which represents an extremely high man-rem 4
condition.
i i
The Inservice Testing (IST) submittals for Unit 2 were addressed by NRC letter of April 8,1983 and subsequently modified by NRC letter of May 2, 1983 Alabama Power Company has discussed some problems identified during the review of the NRC Safety Evaluation Report
?
dated May 2,1983 which will create an unnecessary burden due to i
clerical errors noted in the NRC evaluation such as a check valve included in a list of valves whose position is required to be verified quarterly.
Alabama Power Company and the NRC Staff are discussing these problems and possible solutions.
Again, since the i
Unit 2 refueling outage is scheduled for early September 1983, NRC resolution of these problems is needed by September 1,1983.
Although the ISI and IST submittals are not considered license amendments, it is requested that NRC approval of the above submittals be granted by September 1,1983 to avoid creating a situation where the Unit 2 refueling outage may be unnecessarily impacted.
4.
Service Water Battery Technical Specification Change This proposed change to allow service water battery surveillance testing without shutting down both units at the Farley Nuclear l.
Plant was submitted to the NRC on February 1,1983 with several other editorial and administrative changes.
If NRC approval is not granted in a timely manner, both. units will be required to be shut down in December 1983 in order to test the battery by the end of the surveillance grace period.
Since.the simultaneous shutdown of both units represents a significant logistics concern for Alabama Power Company, it is raauested that review be completed by the requested September 1,1983 date.
Based on subsequent discussions with the NRC Staff, Alabama Power Company will submit a separate administrative technical specificatien change by June 27,1983 to 4
delete the requirement for shutdown of both units to perform the subject battery surveillance testing.
i o
Mr. S. A. Varga June 20, 1983 U. S. Nuclear Regulatory Commission Page 4 5
Turbine Valve Surveillance Technical Specification Change This proposed change to delete turbine valve testing for the remainder of the Unit 2 fuel cycle was submitted on May 27, 1983.
The requested date for NRC approval was July 29, 1983 based on the significant operational transients and the unnecessary processing of radioactive liquid waste associated with this testing near the end of core life.
Based on the operational problems created by this testing require-ment near the end of core life, Alabama Power Company requests that the NRC review be completed no later than August 1,1983 6
Snubber Surveillance Technical Specification Change During the Unit 1 fourth refueling outage, two inaccessible hydraulic snubbers.were declared inoperable.
Based on technical specificaton requirements, additional visual inspections are required to be performed no later than November 1,1983.
These inspections will require a plant outage.
Since the next planned outage is the fifth refueling outage currently scheduled to begin January 24, 1984 (based on 100% fuel burn), a special outage would be required to perform the visual i nspecti ons.
A proposed change for a one-time extension (three months) of the Unit 1 snubber visual inspection requirement was therefore submitted on June 17, 1983.
The requested date for NRC approval was October 1, 1983 based on the potential for an un-necessary plant shutdown if approval is not granted by that date.
I In conclusion, Alabama Power Company requests that the NRC evaluate the above licensing items by the dates identified herein.
Such
. evaluation will avoid the need to resubmit these changes as emergency technical specification changes.
If these items can not be approved as described above, it is requested that the NRC Staff notify Alabama Power Company in order that the provisions of 10 CFR' 50.91 (a)(5) can be exercised.
A summary of these licensing items and schedules is attached.
3
,_,.-,m.,
..m.
.m m,,
Mr. S. A. Varga June 20, 1983 U. S. Nuclear Regulatory Commission Page 5 If you have any questions, please advisa.
Yours truly, M
^
F. L. Claytoni Jr.
l FLCJr/GGY:lsh-D37 Attachment cc:
Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly
'Mr. E. A. Reeves Mr. W. H. Bradford Dr. I. L. Myers Mr. G. C. Lai nas
f ATTA0 TENT Alabana Pwer Conpary Licersing Issues Reluiring EC Approval To Avoid Potential for Inpacting Unit 2 Second Refueling Outage or Causing Unnecessary Plart Shutdsn Requested EC Date Men Subnitted Apprwal Plart Inpact Licersing Iten by AFCo Date
- Occurs Coments
- 1. River Water Systen 12-30-82 07-01-83 08 8 An adninistrative technical specifi -
cation dange will be subnittsi ty 06-27-8 as discussed with the EC Staff on 06-17-8 to avoid the need for EC apprwal of the ertire river water systen subnittal on 07-01-8.
- 2. RCS Pressure Isolation 08-10-82 07-01-83 Unit 2 RC apprwal after 07-01-8 could Valves Secord R.O. inpact the Unit 2 Secord Refueling (09-8)
Outage.
3 ISI and IST Relief 07-25-80 09-01-83 Unit 2 RC apprwal after 09-01-83 could Reluests -
01-10-8 Secord R.0. inpact the Unit 2 Secord Refueling 01 8 (09-8)
Outage.
- 4. Service Water Battery 02-01-83 09-01-8 12 8 An adninistrative te6nical specifica-tion 6ange will be subnitted as discussed in Iten 1 abwe to avoid the need for EC @prwal of the ertire 02-01-8 subnittal on 09-01-8. Such apprwal will negate sinultaneous shut-
&wn of both units.
- 5. Turbine Valve Surveil- 05-27-8 07-29-83 08 8 MC apprwal by 0841-8 will obviate lance Unit 2 operational problens.
- 6. Stubber Surveillance 06-17-83 10-01-8 11 8 EC apprwal is needed to prevert an unnecessary plart shutdown.
- These dates were selected to allow for procedure revisiors, scheduling ard plaming.
I l
L