ML20084Q514

Responds to NRC Addressing Util Responses to NUREG-0737,Item II.F.2 & Generic Ltr 82-28 Re Inadequate Core Cooling Instrumentation Sys.Technically Proven Sys Required.One Oversize Table Encl.Aperture Card Is in PDR

ML20084Q514
Person / Time
Site:	Farley
Issue date:	05/11/1984
From:	Mcdonald R ALABAMA POWER CO.
To:	Varga S NRC
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM GL-82-28, NUDOCS 8405210321
Download: ML20084Q514 (4)

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Allb:ma Powsr Comp 1ny 600 North 18th Street ,

L Post Office Box 2641 l ' Birmingham, Alabama 35291

l. Telephone 205 783-6090

[ce P Nuclear Generation -

Flintridge Building the southem electnc system May 11, 1984 Docket Nos. '50-348

! 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Washington, D.C.' 20555 Attention: Mr. S. A. Varga l Joseph M. Farley Nuclear Plant - Units 1 and 2 Inadequate Core Cooling Instrumentation System Gentlemen:

On April 13, 1984, Alabama Power Company received NRC letter' dated i April 2,1984 addressing Alabama Power Company's responses to NUREG-0737, II.F.2 and Generic Letter 82-28, " Inadequate Core Cooling Instrumentation System." This NRC _ letter requests that, by May 13,1984, . Alabama Power Company " initiate necessary actions to implement procurement and installation of" a reactor vessel level system.at Farley Nuclear Plant -

Units 1 and 2.

One of the bases stated by NRC for this request, is that Alabama Power Compan best-[yreactor has _not carried vessel level]out "its comitment system available to asselect rapidlyand to install the as practicable."

Alabama Power Company contends, however, that it has not failed to satisfy j its commitment for the installation of instrumentation that can detect the j- approach to inadequate core cooling.

l Alabama Power. Cocpany comitted in a February 9, .1981 letter. to install

!. the best available reactor vessel level system as soon as practicable. This

!- comitment was predicated on the non-invasive water level system (a pilot project conducted by Alabama Power Company and EPRI) satisfying its performance expectations. Alabama Power Company informed the NRC in letter i dated August 3,1982 that the non-invasive water level system did not ,

satisfy its performance expectations and that a review of the other -

! available reactor vessel level . systems had begun. In~1etter dated March 10, l' 1983, Alabama Power Company submitted the results of its. review. This

' review stated that the installation of either of the two reactor vessel  ;

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Mr. S. A. Varga May 11, 1984 U. S. Nuclear Regulatory Commission Page 2 level systems available at that time (Westinghouse and Combustion Engineering) was not practicable until resolution of problems regarding their design, installation and operation had been complete and until such a system was determined operationally acceptable by the NRC. Installation of such a system is considered by Alabama Power Company to be a research and development activity similar to that which has already been undertaken by Alabama Power Company; i .e., the non-invasive water level system. It is the judgement of Alabama Power Company that the installation of a technically proven system for operator use in such applications must take precedence over implementation schedular constraints. This position was emphasized during a meeting with NRC senior project management on March 16, 1984 at the Farley Nuclear Plant. Alabama Power Company believes that the position of resolving known problems by active monitoring of and coordination with the system vendors and utilities with installed systems has been proven to be prudent and therefore takes exception with the NRC contention that Alabama Power Company has taken a " wait and see" position.

While the original two commercially available systems have been

" generically approved" by the NRC for installation and operator training and familiarization (Ref: Generic Letter 82-28), neither has received NRC opera-tional approval. Alabama Power Company has been actively monitoring the efforts of utilities that have installed vessel level systems and the system vendors to determine the current status of problem resolution. As a result of this review, the Combustion Engineering system appears to have the most potential for reliable operational service. Alabama Power Company, however, now understands that Technology for Engineering Corporation has a vessel level system that is currently under full prototype testing which may also be acceptable.

Based on the results of the continuing coordination with the vendors and utilities that have been attempting to make reactor vessel level systems operable, Alabama Power Company believes that the remaining technical concerns can be resolved in a timely manner. Alabama Power Company hereby commits to install either the Combustion Engineering or Technology for Energy Corporation reactor vessel level system at Farley Nuclear Plant within three refueling outages for each unit. Implementation on a more expedited schedule could entail significant outage startup delays and could delay implementation of currently schedule modifications associated with the Safety Parameter Display System, Regulatory Guide 1.97 and 10CFR50 Appendix R, Alternate Shutdown Capability.

Attached is a schedule to January 1987 of all work, walkdowns, installations, etc. associated with design, maintenance and licensing activities. It should be noted that for a typical outage sixty design changes can be performed. In addition, major installations typically require one outage for walkdowns and two for installation. Current planning includes completion of approximately seventy design changes per unit over

Mr. S. A. Varga May 11,1984 U. S. Nuclear Regulatory Commission Page 3 the next two outages related to compliance with NRC licensing requirements.

This schedule will be updated in December to reflect the status of design completion, procurement and outage planning. In addition, detailed consideration must be given by Alabama Power Company to the integration of any reactor vessel level system with modifications required under Regulatory Guide 1.97 for Core Exit Thermocouples to preclude unnecessary duplication of systems. Alabama Power Company will address the milestones identified in Enclosure 2 of the NRC April 2,1984 letter after selection of a reactor vessel level system vendor.

If there are any ques'tions, please advise.

Yours truly, bNh R. P. Mcdonald RPM /J AR:ddr-D3 Attachment cc: Mr. L. B. Long Mr. J. P. O' Reilly Mr. E. A. Reeves Mr. W. H. Bradford

e Attachment Farley Nuclear Plant Integrated Schedule For Licensing, Design and Maintenance

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