ML20100E673
| ML20100E673 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/30/1984 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8412060329 | |
| Download: ML20100E673 (10) | |
Text
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Calling Address Alabama Power Company 600 North 18th Strset Post Office Box 2641 a
Birmingham, Alabama 35291 Telephone 205 783-6090 R. P. Mcdonald Senior Vice President Flintridge Building Alabama Power November 30, 1984 Docket Nos. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, !).C.
20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units i 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 Alabama Power Company submitted its Preliminary J
Farley Emergency Response Capability (ERC) Integrated Implementation P1an and Schedule in response to NRC Generic Letter 82-33, " Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability," dated December 17, 1982. A subsequent update to this plan and schedule was provided on December 15, 1983. This letter provides an update to the previous two letters and describer, the subsequent Alabama Power Company efforts and plans with regard to completing each ERC item.
Since December 1983, Alabama Power Company has made substantial progress in all areas of its NUREG-0737, Supplement i effort. The Safety Parameter Display System (SPDS) vendor selection was finalized in January 1984 with extensive design and procurement activities currently in progress. In addition, pre-outage walkdowns have been completed.
Significant progress has been made related to the software program development. The 1985 schedule of activities includes computer hardware installation, HVAC upgrade and acquisition of inputs. The R.G. 1.97 Compliance Reports submitted in March and June of 1984 provided the overall scope of effort necessary to address the provisions of R.G.1.97.
These reports identified approximately 100 physical modifications required to be made to the Farley Nuclear Plant. Design and procurement initiation for these items will be approximately 50% complete in 1984. During 1985, all 3
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8412060329 841130 PDR ADOCK 05000348 l i F
Mr. S. A. Varga November 30, 1984
' U. S. Nuclear Regulatory Commission Page 2 i
4 remaining R.G.1.97 design is scheduled to be completed and procurement initiated. Approximately 50% of the R.G.1.97 Jodifications are currently scheduled to be completed during the 1985 ref aeling outages with the remainder of the installation effort to be completed during the following two outages for each ureit. A purchase award for a Reactor Coolant Inventory Tracking System (RCITS) has been made. The RCITS design is being integrated with the qualified core exit thermocouples (R.G.1.97 parameter). The RCITS is currently scheduled to be implemented no later than the Unit 1 Eighth and
- Unit 2 Fifth Refueling Outages. Ongoing discussions and a meeting with the NRC have also been conducted based on the NRC review of-the Alabama Power Company Control Room Design Review (CRDR) Program Plan. The CRDR Summary Report is currently scheduled to be submitted in the Fourth Quarter of 1986. The Emergency Response Facility (ERF) for Farley Nuclear Plant has been considered operational since October 1982 with display enhancements
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being made in conjunction with the SPDS effort. The Emergency Response Procedures-(ERPs) were implemented in July 1984.
I provides a summary of the specific activities conducted since the December 15, 1983 submittal and the current schedule for completion of the remainder of the Farley ERC Integrated Implementation Plan items. The milestones and schedule dates of each subs 6ction "b" of are considered firm commitments. The final Farley ERC Integrated Implementation Plan and Schedule will be provided to the NRC in November 1985. This will allow sufficient time to evaluate the results obtained from various outage walkdowns, to incorporate the results of i
modifications performed during the Unit 2 Third and Unit 1 Sixth Refueling Outages, and to allow for a final update based on the actual completed 2
At that time Alabama Power Company will be able to make final progress.
commitments based on the actual work completed to date and on the actual work remaining and its impact on future outage critical paths. It would not be possible to make final completion schedule commitments until the precise amount of work remaining is known. To do otherwise would be to make commitments on scheduling of an unknown quantity of work. As stated in the December 15,.1983 letter to the NRC, Alabama Power Company's policy is to 4
incorporate the implementation of licensing items with ongoing plant activities including refueling outages. Typical refueling outages 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.
~ is a graphical presentation of the updated Farley ERC s
Integrated Implementation Plan and Schedule which shows the interrelationship between the SPDS, R.G.1.97, CRDR, ERPs and training efforts as of November 1984. This schedule depicts both the Alabama Power Company goal of SPDS operability within three and one-half years and the current five year ERC commitment schedule.
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- U. S. Nuclear Regulatory Commission Page 3 L
-It should be noted that this three 'and ona-half year SPDS goal is based on the following assumptions:
- 1) - The plant modifications required to install SPDS hardware, provide -
- adequate cooling of the SPDS hardware, and provide data acquisition i
will be completed during the Unit 2 Third and Unit 1 Sixth
~ Refueling Outages.
- 2) The vendor development of software for SPDS will proceed on t-schedule with no major technical difficulties encountered.
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To comply with an NRC request and to ensure accomplishment of the three and one-half year SPDS goal, design for certain Unit 1 R.G.1.97 modifications l
has been delayed to allow a concentration of design and. procurement efforts for SPDS. - The delay of these modifications will not cause a delay in the commitment to complete all R.G.1.97 activities by the Unit 1 Eighth and Unit 2 Fifth Refueling Outages. The plant modifications required for SPDS l.
are extensive and may not be totally accomplished during the time constraints of the three and one-half year goal period. Every reasonable effort to expedite design, procurement and provide highest priority to physical work completion has been taken. The Farley SPDS is a customized
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and totally new system. The software development and testing for this system require extensive vendor effort. The complexity of this software is o
such that technical difficulties may be encountered in the development process. Resolution of these difficulties could delay the software I
development schedule.
It is to be emphasized that the three and onewhalf i
year schedule for SPDS is Alabama Power Company's commitment goal for completion of NURE40737, Supplement 1 activities; however, the commitment deadline for all outstanding ERC items including SPDS remains the Unit 1
- Eighth and Unit 2 Fifth Refueling Outages due to the complicating factors L
described above.
1 Alabama Power Company believes that the completion of the scheduled activities described herein, the ongoing coordination with the NRC Project Manager for negotiated r,ubmittal completion dates, and the yearly submittals of an updated schedule for future activities is a continued demonstration of goodwfaith efforts to meet or exceed the NRC provisions of Supplement 1 to.
NURE40737 and to safely implement a fully integrated and cost effective enhancement to the present Farley ERC system within a reasonable time frame.
If you have any questions, please advise.
j Yours very truly R. P. Mcdonald r
RPM / JAR:bdh-D34 Attachments cc: See Page 4 1
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l1 Mr. S. A. Vc.rga
.Novemb:r 30, 1984 U. S. Nuclear. Regulatory Commission.
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- Mr. J. P. O'Reilly Mr. E. A. Reeves Mr.-W. H.-Bradford i
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Farley ERC Integrated Implementation P1an and Schedule 11.
Safety Parameter Display System (SPDS) a.
' Status of Activities Since December 15,1983 Alabama Power _ Company has finalized a contract for the SPDS and has developed a detailed Technical Description document. This document defines'all aspects of the Farley Nuclear Plant SPDS vendor implementation effort (e.g., hardware, software, man-machine interface, licensing suport and training). This effort was followed by the development and finalization of the acceptance criteria,: test-plan, SPDS inputs, input test procedures, and a detailed design implementation schedule. The design process for SPDS has been initiated and has required extensive Alabama Power Company involvement especially in the development of the
- Criticial Safety Function Status Tree Displays. The Design Specification for the SPDS should be finalized 'during December 1984. The Design Specification is the. document which defines the SPDS in sufficient' detail to serve as the governing document for the design process. The Design Specification also provides detailed information on areas such as data acquisition, database information fields and man-machine interface.
In parallel with the above efforts, detailed design has been developed for additional computer room requirements (power supplies, HVAC modifications, etc.), SPDS hardware installation and acquisition of all necessaif inputs. Procurement and outage planning for implementation of the computer room modifications are currently in progress to support
' implementation during the Unit 2 Third and Unit 1 Sixth Refueling Outages.
b..
Revised Milestone and Completion Dates Milestone Completion Date Finalize and issue SPDS October 14, 1983 specification for bids (Complete)
Submittal of Safety November 30, 1983 Analysis and Implementation Plan (Complete)
Fully operable SPDS Unit 1, 8th R.0.
(March 1988)
Unit 2, 5th R.0.
(October 1987) 3-1/2 year goal date:
October 1986 for both units Operator Training with SPDS Unit 1, 8th R.0.
(March 1%8)
Unit 2, 5th R.0.
(October 1987) 3-1/2 year goal date:
October 1985 for both units
i
. to Alabama Power Company's November 30, 1984 Letter:
Subject:
NRC Generic Letter 82-33 Page 2 c.
Major 1985 Activities Modifications to the Farley computer rooms (HVAC upgrade, power supply, etc.), which are required to support SPDS hardware installation, are scheduled for the Unit 1 Sixth and Unit 2 Third Refueling Outages.
The installation of the SPDS hardware in the computer rooms and acquisition of inputs from the field are also scheduled for these outages. The development and testing of SPDS software will be ongoing throughout 1985. In parallel with the software development, test procedures for the factory acceptance test will be developed, reviewed and finalized. The factory acceptance test is scheduled to begin in November 1985.
2.
Regulatory Guide 1.97 (R.G.1.97) a.
Status of Activities Since December 15, 1983 The Unit 1 and 2 Compliance Reports were submitted to the NRC on June 29 and tiarch 30, 1984, respectively. These reports detailed the compliance of Farley Nuclear Plant with each of the provisions of R.G.1.97 and, for all deviations identified, either provided justifications or proposed modifications to complete compliance. Upon implementation of the modifications described in these reports, Farley Nuclear Plant will be considered to be in compliance with R.G.1.97.
Detailed design,
, procurement and installation schedules have been developel to implement the required modifications prior to startup for the Unit 1 Eighth and Unit 2 Fifth Refueling Outages. Certain environmental qualification modifications of R.G.1.97 instrtments were implemented during the Unit 1 Fifth Refueling Outage to satisfy the provisions of 10CFR50.49.
In addition, a purchase award for a Reactor Coolant Inventory Tracking System (RCITS) has been made. Determination of RCITS vendor responsibilities; development of fabrication, design and procurement schedules; and the integration of core exit thermocouples with the RCITS have been initiated.
b.
Revised Milestone and Completion Dates Milestone Completion Date Finalite 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 30,1984 - Unit 2 Compliance Report June 29,1984 - Unit 1 (Complete)
. to Alabama Power Company's November 30, 1984 L;tter:
Subject:
NRC Generic Letter 82-33 Page 3 Ccmpletion of R.G.1.97 U*it 1, 8th R.0.
modifications (tarch 1988)
Unit 2, 5th R.0.
(October 1987)
Note: This schedule was accepted by NRC letter dated June 12, 1984.
c.
Major 1985 Activities Certain environmental qualification modifications of R.G.1.97 instruments will be implemented during the Unit 2 Third and Unit 1 Sixth Refueling Outages to satisfy the provisions of 10CFR50.49.
In addition, twenty-two other separate modifications for Unit 2 and sixteen other separate modifications for Unit 1 have been scheduled for implementation during the 1985 refueling outages dependent upon material procurement and outage critical path scheduling. During 1985 all remaining R.G.1.97 design is scheduled to be completed and procurement initiated. The remainder of R.G.1.97 modifications are currently scheduled for installation during the following two outages for each unit.
3.
Control Roan Design Review (CRDR) a.
Status of Activities Since December 15, 1983 Alabama Power Company received NRC comments on its CRDR Program Plan by letter dated March 9,1984. Subsequent to this letter, Alabama Power Company worked with a Human Factors Specialist to revise the CRDR Program Plan and develop a detailed implementation plan. On July 19, 1984 Al abama Power Company participated in an NRC/NUTAC meeting to discuss CRDR.
Following this meeting a detailed Farley Nuclear Plant implementation schedule was developed which incorporated the availability of Farley Nuclear Plant and CRDR Review Team personnel. On July 25, 1984 Alabama Power Company personnel and the NRC Staff met to discuss the Alabama Power Company Program Plan. By letter dated November 20, 1984, Alabama Power Company transmitted a response te the NRC comments.
b.
Revised Milestone and Completion Dates Milestone Completion Date Submittal of CRDR Program Plan October 31, 1983 (Complete)
Submittal of CRDR Summary Report Fourth Quarter 1986 including schedules to resolve Human Engineering Discrepancies
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. to Alabama Power Company's November 30, 1984 Letter:
Subject:
NRC Generic Letter 82-33 Page 4 Completion of modifications Unit 1, 8th R.O.
resulting from the resolution of (March 1988) any Human Engineering Discrepancies Unit 2, 5th R.0.
(October 1987) c.
Major 1985 Activities All preparation work for the CRDR survey and task analysis is scheduled for completion by the Third Quarter 1985. This includes development of all engineering and operating questionnaires, survey checklists, the completion of task identification for emergency procedures, and the completion of the operating experience review.
The control room surveys and operator walkthroughs are scheduled for completion by the Fourth Quarter 1985. All Human Engineering Discrepancies are currently scheduled to be identified during 1985.
4.
Emergency Response Facilities (EllFs) a.
Status of Activitiec Since December 15, 1983 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 SPDS CRTs in the Technical Support Center.
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 October 1985 implementation plan Complete ERF display plan Unit 1, 8th R.0.
required modifications, if (March 1988) necessary (to be accomplished in Unit 2, 5th R.0.
conjunction with completion of (October 1987)
SPDS) 3-1/2 year goal date:
October 1986 for both v:its m.
' to Alabama Power Company's November 30, 1984 Letter:
Subject:
NRC Generic Letter 82-33 Page 5 c.
Major 1985 Activities ERF enhancement will be provided by the implementation of SPDS CRTs in the Technical Support Center. Design, procurement and installation schedules will be established based on SPDS efforts and a Technical Support Center CRT implementation plan will be prepared by October 1985.
5.
Emergency Operating Procedures (EOPs) a.
Status of Activities Since December 15, 1983 Plant-specific Emergency Response Procedures (ERPs) were implemented at Farley Nuclear Plant in July 1984.
b.
Revised Milestone and Completion Dates Milestone Completion Date Submittal of PGP July 29,1983 (Complete)
Implementation of upgraded ERPs July 1984 (Complete)
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A Farley ERC Integrated Implementation Plan and Schedule (Graphical Presentation)
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