ML20099L315

Application for Amends to Licenses NPF-2 & NPF-8,revising Tech Spec Sections 3,4 & 6 as Supplemental Response to Generic Ltr 83-43 Re LER Reporting Requirements of 10CFR50.72 & 50.73

ML20099L315
Person / Time
Site:	Farley
Issue date:	11/26/1984
From:	Mcdonald R ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20099L319	List: ML20099L315 ML20099L329
References
GL-83-43, NUDOCS 8412010084
Download: ML20099L315 (4)

Text

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.M17ng Address'- .

Alstnma Power company '

.' 600 North 18th Street.-

Post Office Box 2641 -

Birmingham, Alabama 35291

.. Telephone 205 783-6090 R. P. Mcdonald

. Senior Vice President Flintridge iscilding AlabamaPower November- 26,1984 Docket No. 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-Supplemental Response to Generic Letter 83-43, Reporting Requirements of 10CFR50.72 and 10CFR50.73

Gentlemen:

Pursuant w recent communications with.the NRC Staff, this letter supplements Alabama Power Company's September 14, 1984 letter which proposed changes to the Farley Nuclear Plant Technical Specifications

' Sections 3, 4 and 6 and the Bases of Section 3/4 to implement the new reporting requirements of 10CFR50.72 and 10CFR50.73 (LER Rule). ,

This supplement reflects the final technical specification changes necessary to implement the new LER Rule and includes'the comments of the NRC Staff. 'Each of the changes resulting from discussions with the NRC

Staff is provided in Attachment 1.

! In order to facilitate the issuar.ce of the proposed technical specification change'which -implements the new LER Rule,- all the proposed

, changed pages from the February 3, July 6 (Item 1 only), and September l~ 14 technical. specification change requests and this supplement have been l- compiled and are provided in Attachment 2. It-should be noted, that l  : page 6-21 of Attachment 2 reflects not only the page number. change as a

! result of the new LER Rule, but also a change to technical specification u 6.10.2.n which was included in the July 6,1984 proposed technical specification change for deleting the snubber tables. Currently the .

snubber technical specification change is-scheduled to be completed by-the NRC Staff prior to this LER Rule technical specification' change; L therefore, in order to ensure that' the correct page is issued, the L snubber-technical specification change is included in pageL6-21 of Attachment 2.

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Mr. S. A. Varga November 26, 1984 Page 2

.U. S. Nuclear _ Regulatory Comission Alabama Power Company requests that the NRC review and approve

-these proposed changes to the Technical Specifications by January 21, 1985 in order to eliminate the inconsistency between the new LER Rule and the existing technical specifications.

Because the original proposed technical specification change of September 14, 1984 and this supplement are being submitted at the request of the NRC and since Generic Letter 83-43 stated that no license j amendment fee is required for changes which implement the Generic Letter, no License Application Fee is enclosed.

If you have any questions, please advise.

Yours very trul ,

N b R. P. Mcdonald RPM /CJS:ddb-D-Tech Spec-II Attachments cc: Mr. L. B. Long Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford Mr. G. F. Trowbridge Mr. Dan Turner

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l Attachment 1 1)' Change to : Technical Specification 3.4.9, Modes 1, 2, 3,~ 4 and 5 Action "a" )

(Both Units 1 and 2). This change was identified as item 5 in Attachment 1 '

of the September 14, 1984 Alabama Power Company submittal.

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.- .In the September 14, 1984 submittal, Al abama Power Company proposed to delete Reportable Occurrence submittals from Technical Specification Sections 3 and 4, _ pursuant to 10CFR50.73 and Generic Letter 83-43. The NRC

> . Staff stated during recent telephone conversations that an annual report

, - would be required in lieu of the current Reportable Occurrence, if the l reactor coolant specific activity limit of 1.0 microcurie / gram or 100/E were r

exceeded.' An annual reactor coolant system specific activity report is included in Attachment 2 as a' new Technical Specification 6.9.1.13 (page 6-20 both units) .. This proposal is consistent with the most recent revision g of the Westinghouse Standard Technical Specifications.

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2) Change to Technical Specifications 3.5.2, Action "b" and 3.5.3, Action "c" .

(both ' Units 1 and 2) . This-change was identified as item 6 in Attachment 1 F of the September 14, 1984 Alabama Power Company submittal .

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In the September 14, 1984 submittal, Alabama Power Company proposed to delete submittals which were already required to be reported pursuant to

! 10CFR50.73. During recent telephone conversations, the NRC Staff stated that certain information which is not specifically included in the applicable 10CFR50.73 provisions is necessary for NRC evaluation; therefore, a Special Report would be required.in the event of an ECCS actuation.

Alabama Power Company hereby withdraws the proposed changes to Technical Specification 3.5.2 and 3.5.3 which were included in the September 14, 1984

letter.

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3) Change to Technical Specification 4.7.10.3 (both Units 1 and 2). Tni s .

change was identified as item 8 in Attachment 1 of the September 14, 1984 Alabama Power Company submittal.

In the September 14, 1984 submittal, Alabama Power Company proposed to

delete technical specification reports which were no longer required.

!' pursuant to 10CFR50.73. Since a record of all sealed source and fission

detector leak tests and results, as well as a record of annual physical inventory of all sealed source material of record, are . required to be i maintained for NRC audit for a minimum of 5 years-(Technical Specification 6.10.1) and since the stated purpose' of the LER Rule was .to reduce unnecessary-reporting, Alabama Power Company proposed that Technical Specification 4.7.10.3 be deleted.

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.The NRC Staff stated during recent telephone conversations that an annual

seal source leakage report will- continue' to be required in the Technical >

Specifications. An annual sealed source leakage report is included in ,

Attachment 2 as a new Technical Specification 6.9.1.14 (page 6-20 for both p units). ,

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Attachipent 1 Page 2-

4) Change to Technical Specification 3.12.1, action "b" (both Units 1 and 2).

This change was identified as item 11 in Attachment 1 of the September 14, 1984 Alabama Power Company submittal.

In the September 14, 1984 submittal, Alabama Power Company proposed to delete action "b" in its entirety. Subsequent communications with the NRC Staff have indicated that the NRC would prefer that the action statement be modified to require a Special Report rather than delete it in its entirety.

Alabama Power Company has revised page 3/412-1 for both units to reflect the requirement for a Special Report.

5) In the September 14, 1984 submittal, Alabama Power Company proposed to add a new Annual Diesel Generator Reliability Data Report pursuant to Generic Letter 84-15. The NRC Staff stated during recent telephone conversations that the annual report description should be clarified to ensure that the information identified in section C.3.b of Regulatory Guide 1.108 Revision 1,1977 is provided in the Annual Diesel Generator Reliability Report.

The requested clarification' has been included in Attachment 2 (page 6-19 both units) . This proposed change is consistent with the reporting information requirement of the existing Technical Specifications.

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