ML20082U892
| ML20082U892 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/15/1983 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Varga S NRC |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8312190210 | |
| Download: ML20082U892 (11) | |
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1 Address ia Power Cornpany arth 18th Street Office Box 2641 aingham, Alabama 35291 ephone 205 783-6081 F. L Clafton, Jr.
)
' Senior Vice President Fhntridge Budding
/Mabailla POh'CI~
December 15, 1983 Docket Nos. 50-248 50-364 l
Director, Nuclear Reactor Regulation
{
U. S. Nuclear Regulatory Ccmission l
Washington, D.C.
20555 Attention:
Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 NRC Generic Letter 82-33, " Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability," Dated December 17, 1982 Gentlemen:
On April 15, 1983 Farley ERC Integrated Implementation Plan and Schedule in res ary NRC Generic Letter 82-33, " Supplement i to NUREG-0737 - Requi onse to Emergency Response Capability," dated December rements for 15, 1983 17, 1982 the Preliminary Farley Emergency Response Capabilitresp 15, 1983 ecember Integrated Implementation P1an and Schedule based on completio y (ERC) scheduled activities, further planning, completion of conceptual design n of and schedular advancements.
Preliminary Farley ERC Integrated Implementation PlanThis letter 15, 1983 Schedule and the three and one-half year Safety Parameter Displ and (SPDS) implementatica goal.
In addition, Alabama Power Company say System efforts and plans with regard to each ERC item are described herein The April 15, 1983 Power Company's initial response to Generic Letter 82-33subniittal reference letter Alabama Power Comoany discussed efforts to resolve NRC
. In this provisions en88N8ab pas,.$
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Mr. S. A. Varga Dsctmber 15, 1983 Nuclear Regulatory Comission Page 2 for emergency response capability. These efforts included active participation in Nuclear Utility Task Action Comittees on Emergency Response Capabilities and Westinghouse Owners Group efforts. A milestone schedule was also provided which graphically displayed the timetable for completing actions associated with each of the basic NUREG-0737 Supplement 1 provisions as well as their integration and interface.
It was noted that additional efforts would be required prior to completion of a final integrated plan and schedule since much of the information needed was beyond the total control of Alabama Power Company. Finally, the adequacy of the present emergency response capabilities at Farley Nuclear Plant was described in detail to justify continued operation pending completion of remaining ERC enhancements.
Subsequent to the April 15, 1983 submittal to the NRC, Alabama Power Company met with the Farley NRC Project Manager at the Farley Nuclear Plant and the Alabama Power Company Corporate Office from May 3
.through 6,1983 to discuss the Preliminary Farley ERC Integrated Impletrentation Plan and Schedule. At this meeting the development and basis of the SPDS three and one-half year goal was also discussed.
During the next four months, the dates in the April 15, 1983 schedule were negotiated with the NRC Staff. As a result of this negotiation, Alabama Power Company advanced portions of the implementation schedule with supplemental milestone and completion dates as documented in letters of August 5 and September 22, 1983. Completion dates for certain milestones could not be provided at that time since certain critical.information was not available.
As described in the April 15, 1983 Preliminary Farley ERC Integrated Implementation Plan and Schedule, implementation of the SPDS is scheduled for five years. A goal of three and one-half years, however, has been established for an operational SPDS. The five year schedule is a more realistic schedule since it will allow an additional outage to complete engineering walkdowns necessary to finalize designs and complete installation planning. The three and one-half year goal assumes that engineering walkdowns, installation, software / hardware modifications, and final acceptance testing can be completed within two outages.
SPDS implementation has been included in an integrated implementation schedule of all NRC commitments and other design modifications and maintenance activities. This schedule includes implementation of commitments related to IE Bulletins, Generic Letters, CFR provisions such as environmental qualification and Appendix R, as well as NUREG-0737, Supplement 1 and other significant design modifications and maintenance activities. Implementation of these licensing items must be coordinated with ongoing plant activities including refueling outages. Typical outages of this nature at
i Mr. S. A. Varga Decemb::r 15, 1983 Nuclear Regulatory Comission Page 3 Farley Nuclear Plant are six weeks in duration with installation of all modifications on a preplanned and packaged basis.
It is the philosophy of Alabama Power Company to perform only refueling related work on the outage critical path unless a safety issue is involved. This requires that all design reviews be completed, manpower requirements assessed, detail r.ork sequences identified, acceptance testing planned, field procurement identified and all material received onsite prior to the outage. Following award of contract, Alabama Power Company and the SPDS vendor will formalize responsibilities and schedules for design, manufacture, implementation and testing of the SPDS. Every effort will be made to advance the five year schedule and have an operational SPDS within the three and one-half year goal period (fourth quarter,1986). provides a summary of the specific activities conducted since the April 15, 1983 submittal and the current schedule for completion of the Farley ERC Integrated Implementation Plan and Schedule. The milestones and schedule dates of each subsection "b" of are considered firm commitments. Many of the actions to be completed beyond 1984 are dependent on activities not yet fully defined; as these activities are better defined, Alabama Power Company will update this submittal. An update to the Farley ERC Integrated Implementation Plan and Schedule will be provided to the NRC in September 1984. This will allow sufficient time to evaluate the results obtained from various walkdowns, to finalize milestone schedules, and to incorporate the results of modifications performed during the Unit 1 Fifth Refueling Outage. is a graphical presentation of the updated Farley ERC Integrated Implementation Plan and Schedule which shows the interrelationship between the SPUS, Emergency Response Facility (ERF),
R.G.1.97, Control Room Design Review (CRDR), Emergency Operation Procedures (EOP) and training efforts as of December 1983. This schedule depicts both the Alabama Power Company goal of SPDS operability within three and one-half years and the curent five year implementation schedule for the remaining ERC items.
Alabama Power Company believes that completion of the scheduled activities described above, coordination with the NRC Project Manager for negotiated submittal / completion dates, completion of conceptual designs, and submittal of the proposed plan and schedule for future activities is a continued demonstration of good-faith efforts to meet or exceed the HRC provisions of Supplement 1 to NUREG-0737 and to safely implement a fully integrated and cost-effective enhancement to the present Farley ERC system within a reasonable time frame.
j
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Mr. S. A. Yarga December 15, 1983 Nuclear Regulatory Comission Page 4 If you have any questions, please advise.
Yours very trul f'l/
6%
i F
g. L. Clayton, Jr.
FLCJr/ JAR:grs-D13 Attachments cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford Farley ERC Integrated Implementation Plan and Schedule 1.
Safety Parameter Display System (SPDS) a.
Status of Activities Since April 15, 1983 Alabama Power Company has defined the SPDS to be the parameters necessary to monitor the Westinghouse Owners Group Critical Safety Function Status Trees and justified this definition in a November 30, 1983 letter to the NRC providing the SPDS Safety Analysis and Implementation Plan. A review of potential SPDS vendors that included a survey of nuclear utilities, preliminary meetings with vendor representatives, and initial assessments of vendor capabilities and expertise has been conducted. Concurrent with this effort, a conceptual design for the SPDS was developed and translated into an equipment specification which was then issued for bids. All SPDS bids were received by November 28, 1983 and are currently being evaluated. The conceptual design entails an upgrading of the current plant process computer and installation of a data-link to a new SPDS computer. The data-link will provide the parameter inputs required for the new SPDS computer.
All activities necessary to install an SPDS that are not dependent upon the final selection of an SPDS vendor have been initiated. These activities include:
1.
Determination of additional inputs not currently in the plant process computer (Complete).
2.
Design for the additional SPDS inputs to the plant process computer (Initiated with completion scheduled for May 1984).
3.
Evaluation of additional computer room requirements; e.g.,
power supply, HVAC, computer hardware location (Conceptual design complete).
4.
Upgrade of the plant process computer to allow for use of the data-link conceptual design (Contract awarded).
5.
Preliminary vendor walkdowns conducted during November 1983. Additional walkdowns are scheduled for the Unit 1 Fifth Refueling Outage and the Unit 2 Third Refueling Outage.
Meetings have been conducted with Alabama Powee Company's design organizations to ensure proper integration of all efforts.
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ to Alabama Power Company's Decembsr 15, 1983 Letter;
Subject:
Page 2 b.
Revised Milestone and Completion Dates Milestone Congletion Date
- Finalize and issue SPDS October 14, 1983 specification for bids (Complete)
- Submittal of Safety November 30, 1983 Analysis and Implementation Plan (Complete)
(March 1988)
Unit 2, 5th R.0.
(October 1987) 3-1/2 year goal date:
October 1986 for both units
- Operator Trainirg with SPDS Unit 1, 8th R.0.
(March 1988)
Unit 2, 5th R.0.
(October 1987) 3-1/2 year goal date:
October 1936 for both units c.
Major 1984 Activities The selection of the SPDS vendor is expected to be completed during January 1984.
In the subsequent three month period, formal design, procurement and installation schedules will be established. These schedules will be developed utilizing the Alabama Power Company goal of an operable SPDS within the three and one-half years; however, it should be noted that the scheduled five year timeframe may be necessary to minimize critical path outage time and allow for adequate preplanning, walkdowns, etc.
Following establishment of vendor / utility responsibilities, vendor design and SPDS harkare manufacturing will begin. Unit i design walkdowns are scheduled for the Fifth Refueling Outage and walkdowns for both units are to be conducted at power during 1984. Also in 1984, SPDS computer room modifications are expected to be completed and a detailed system description of SPDS will be developed. As many of the SPDS parameters as practical not presently in the Unit 1 plant computer are scheduled to be added during the Unit 1 Fifth Refueling Outage.
I to Alabsma Power Company's December 15, 1983 Letter;
Subject:
NRC Generic Letter 82-33 Page 3 2.
Regulatory Guide 1.97 (R.G.1.97) a.
Status of Activities Since April 15, 1983 Alabama Power Company has identified the scope of work and support organizations that will be necessary to assess its compliance with the provisions of R.G.1.97.
This entailed meetings with the design organizations in which a methodology for assessing and documenting the R.G.1.97 review was developed. Criteria were defined for selecting the equipment that required modification during the upcoming Unit 1 Fifth Refueling Outage and Unit 2 Third Refueling Outage to comply with the provisions of 10CFR50.49. Design to upgrade forty-one R.G.1.97 instrument channels and the core exit thermocouples during the Unit 1 Fifth Refueling Outage has been scheduled for implementation dependent upon procurement of critical items which is currently being expedited.
In additien, schedules have been established to complete required compliance review, evaluation of plant-specific design variances from the guidance of R.G.1.97, and/or determination of potential modifications, alternatives and justifications necessary to establish compliance with applicable R.G.1.97 provisions.
b.
Revised Milestone and Completion Dates Milestone Complcticu Ca.:
- Finalize R.G.1.97 design basis August 1983 (Complete)
- Establish plan for Category 1 October 1983 display (Complete)
- Submittal of R.G.1.97 March 1984 - Unit 2 Compliance Report June 1984 - Unit 1
- Completion of R.G.1.97 Unit 1, 8th R.0.
modifications (March 1988)
Unit 2, 5th R.0.
(October 1967) c.
Major 1984 Activities The Unit 1 and 2 Compliance Reports will identify deviations from the guidance of R.G.1.97 and, as available, provide justifications, proposed alternatives and schedules for any necessary modifications. Detailed design, procurement and to Alabara Power Company's Decemb:r 15, 1983 Letter;
Subject:
'Page 4 installation schedules will be developed to implement any required modifications to ensure completion prior to startup of the Unit 1 Eighth Refueling Outage and the Unit 2 Fifth Refueling Outage. Certain environmental qualification modifications of R.G.1.97 instruments will be implemented during the Unit 1 Fifth Refueling Outage to satisfy 10CFR50.49.
3.
Control Room Design lleview (CRDR) a.
Status of Activities Since April 15, 1983 On October 31, 1983, Alabama Power Company submitted the Farley Control Room Design Review (CRDR) Program P1an. This plan was developed using guidance provided by the Nuclear Utilities Task Action Connittee on CRDR and described the manner in which Alabama Power Company will conduct a human factors review of the Farley Nuclear Plant control rooms.
In addition, the plan specifically addressed the provisions of NUREG-0737 Supplement 1 and described how previous Alabama Power Company CRDR efforts will be utilized to provide for a comprehensive review.
In support of the CRDR plan, Alabama Power Company has also begun gathering the information necessary to conduct the operating experience raview. In addition, a human factors vendor has been selected to participate in the planning, implementation and review of CRDR activities.
b.
Revised Milestone and Completion Dates Milestone Completion Date
- Submittal of CRDR Program Plan October 31, 1983 (Complete)
- Submittal of CRDR Summary Report Updated schedule to be including schedules to resolve submitted by September Human Engineering Discrepancies 1984.
- Completion of modifications Unit 1, 8th R.0.
resulting from the resolution of (March 1988) any Htanan Engineering Discrepancies Unit 2, 5th P. 0.
(October 1987)
- d. Major 1984 Activities Alabama Power Company has scheduled the execution phase of the CRDR to begin in the third quarter 1984. The CRDR execution phase is described in Alabama Power Company's CRDR Program Plan l
_ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ to Alabama Pcwer Ccmpany's Dacember 15, 1983 Letter;
Subject:
NRC Generic Letter 82-33 Page 5 submitted October 31, 1983 and includes an operating experience review, control room survey and task analysis for emergency operations. Upon determination of the specific Human Engineering Discrepancies (HEDs), Alabama Power Company will begin their assessment to determine resolutions for each identified HED.
4.
Emergency Response Facility (ERFs)
Status of Activities Since April 15, 1983 a.
As stated in Alabama Power Company's April 15, 1983 submittal to the NRC, the ERFs are considered to be fully operational as demonstrated during the 1983 Farley Nuclear Plant Emergency Exercises. Provisions have been made, however, to install an SPDS display in the Technical Support Center (TSC).
b.
Revised Milestone and Completion Dates Milestone Completion Date
- Operational ERFs October 1982 (Complete)
- Develop ERF display design November 1983 criteria (Complete)
- Prepare ERF display Updated schedule to be impiementation p1an submitted by September 1984.
- Complete ERF display plan Unit 1, 8th R.0.
required modifications, if (March 1988) necessary (to be accomplished in Unit 2, 5th R.O.
conjunction with completion of (October 1987)
SPDS) 3-1/2 year goal date:
October 1986 for both units.
- c. Major 1984 Activities ERF enhancement will be provided by the implementation of SPDS displays in tne TSC. Design, procurement and installation schedules will be estaolished based on SPDS efforts and a i
display implementation plan will be prepared.
i
__ to Alabama Pow:r Company's December 15, 1983 Letter;
Subject:
NRC Generic Letter 82-33 Page 6 5.
Emergency Operating Procedures (EOPs) a.
Status of Activities Since April 15, 1983 On July 29, 1983, Alabama Power Company submitted the Procedure Generation Package (PGP) tc the NRC. The PGP provided the program for converting the Westinghouse Owners Group Emergency Response Guidelines (ERGS) into plant-specific Emergency Response Procedures (ERPs), the Writers Guide for ERPs, and the ERP Verification, Validation and Training programs. This submittal was the culmination of extensive Alabama Power Company participation in the development of the Westinghouse Owners Group ERGS and Alabama Power Company review of the programs and schedules. Development of plant-specific ERPs has been initiated and is being developed in accordance with the PGP.
b.
Revised Milestone and Completion Dates Milestone Completion Date
- Submittal of PGP July 29, 1983 (Complete)
- Implementation of upgraded ERPs July 1984 c.
Major 1984 Activities By July 1984, the ERPs will be prepared, verified and implemented with training completed. ERPs will be updated and operators trained as new procedures are developed based on the approved Westinghouse Owners Group generic Emergency Response Guidelines, Revision 1.
Farley ERC Integrated implementation Plan and Schedule (Graphical Presentation) 4
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