ML20094G597

Submits Addl Info Re 10CFR50,App R Schedular Exemption for Alternative Shutdown Mods.Bases for Schedular Exemption Until Unit 1 Seventh & Unit 2 Fourth Refueling Outages to Completed Mods Provided

ML20094G597
Person / Time
Site:	Farley
Issue date:	08/06/1984
From:	Mcdonald R ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8408130374
Download: ML20094G597 (2)

Text

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-: ' Mailing Address ,

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i Alibima Power Comp 2ny ~ <

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J -.'600 North 18th Street '

' Post Offica Box 2641 :

,.' ' Birmingham. Nabama 35291.

.c  ; Telepnone 20$ 783-6090

~ R. P. Mcdonald. . . .

=' - Senior Vice President -

1 riintriose Buiio.no AlabamaPower the southem em:rc sys'em August' 6, 1984 ~

1Dohket Nos'. 50-348. .

50-364-

' Director,- Nuclear Reactor: Regulation 1U... S. Nuclear Regulatory Comission Nashington, D.C. -20555 l Attention: Mr. S. A. Varga

.Farley Nuclear Plant - Units 1 and 2 Appendix R, Basis for Schedular Exemption

Gentlemen:

As a result of a request by the NRC Staff, Alabama Power Company is

,providing additional information on the 10CFR50, Appendix R schedular

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. exemption. for the alternative shutdown modification. - Alabama Power Company

~ 1s required by 10CFR50.48 to provide Alternative Shutdown Capability in

'accordance.with 10CFR50, Appendix R for Farley Nuclear Plant, Units .1 and 2, by the end.-of the sixth and third refueling outages, respectively. By.

4 letter dated June 18, 1982, Alabama Power Company ~ requested:an exemption until the Unit 1 seventh and Unit 2 fourth refueling outages for completion of the Appendix R; alternative shutdown modification. The basis for this schedular exemption is as follows:-

< -(1) Final design.and Jocu'enent activities were initiated upon:

l:  : receipt of NRC approval of the design description by letter dated

. August _26, 1983.-

(2) In April, 1984, sufficient design-for procurement of engineered items was issued and purchase orders initiated. Procurement lead

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times for some of the equipment (e.g... signal converter cards) are

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typically; on the order of 48 weeks. This is based on the interface.requiremen.ts with Class IE components requiring design, field fabrication, and seismic testing prior to installation.

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Mr. S. ' A. Varga Page 2 (U. S. Nuclear-Regulatory Comission August 6,1984 (3) Bs :ause of NRC additions (i.e., neutron monitor and Tcold) to the original Alabama Power Company design description of the alternative shutdown modification, final design time for Unit 1 and 2 has increased from the estimated 8 months described in

. Alabama Power Company's June 18, 1982 letter to approximately 12 months.

(4) Detailed installation schedules cannot be established until the issuance of the final design, however, the current installation schedule for work inside containment requiring unit shutdown is

. estimated at four weeks. This estimate does not include allowance for' resolution of field encountered problems that typically occur during the installation of large design changes'

such as the alternative shutdown modification. This design change requires substantial cable additions, installation of new cable trays both inside and outside of containment, and installation of the neutron monitor in the reactor cavity. The installation, inspection, .and verification of the alternative shutdown modification are therefore anticipated to require more than one refueling outage. 'This-is based on Alabama Power Company's planned. refueling. outage schedule of five weeks for each unit, which allows approximately four weeks inside containment for modifications to the primary systems.

. Alabama Power Company believes the above demonstrates need for the schedular. exemption requested in referenced letter dated June 18, 1982. If-there are any questions,'please advise.

Yours very tru ,

1 R. P. Mcdonald I rpm /DHJ:ddb-D14 cc: . Mr. ' L.- B. Long

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( ~ Mr. _ J. P.-( O' Reilly

Mr.- E. A. Reeves-

Mr. W. H. Bradford-4 m

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