ML20129E768

Forwards Indication of Current Evaluation & Status of Review of 820208,1019 & s Requesting That Certain License Conditions Be Formally Closed.No Response Required

ML20129E768
Person / Time
Site:	Farley
Issue date:	05/23/1985
From:	Varga S Office of Nuclear Reactor Regulation
To:	Mcdonald R ALABAMA POWER CO.
References
CIVP-A-084, CIVP-A-84, NUDOCS 8506060592
Download: ML20129E768 (12)

Text

{{#Wiki_filter:* May 23, 1985 Docket No. 50-364 -

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                                                .                NRC DPR L PDR            Gray File ORB #1 Rdg       HThompson Mr. R. P. Mcdonald                        OELD              CParrish Senior Vice President                      EReeves          EReeves 2 Alabama Power Company                     ACRS 10           EJordan Post Office Box 2641                      BGrimes           JPartlow Birmingham, Alabama 35291                 MSlosson          DLangford WGKennedy         WJRoss

Dear Mr. Mcdonald:

WHazelton JVoglewede

SUBJECT:

EVALUATION AND STATUS OF LICENSE CONDITIONS FOR JOSEPH M. FARLEY UNIT 2 By letters dated February 8 and October 19, 1982, and January 7, 1983, which superseded the October 19, letter, you requested that certain license conditions be formally closed by the NRC. By letter dated October 22, 1982, you noted that another license condition was satisfied. We have completed our reviews of these submittals. The enclosure to this letter indicates the current evaluation and status of our review of your submittals relating to the identified license conditions for Facility Operating License No NPF-8 dated March 31, 1981. No response to this letter is required. However, you may contact the NRC Project Manager, Mr. Edward A. Reeves, at 301-492-7386, should you have any questions. Sincerely,

                                                  /s/SVarga Steven A. Varga, Chief Operating Reactors Branch #1 Division of Licensing

Enclosure:

As stated cc w/ enclosure: See.next page

     *See previous white for concurrences                3 ORB #1:DL*        ORB #1:DL*    ORB #1:DL             :DL CParrish          MSlosson;ps   E eeves 3/27 /85          3/24 /85          85 8506060592 850523 PDR    ADOCK 05000364 P                     PDR

   -Docket No. 50-364,                           DISTRIBUTION Docket File     NRC DPR L PDR           Gray File ORB #1 Rdg      HThompson Mr. . R. P. - Mcdonald                       OELD            CParrish Senior Vice President                        EReeves         EReeves'2 Alabama Power Company                        ACRS 10         EJordan Post Office Box 2641                         BGrimes         JPartlow Birmingham, Alabama 35291                    MSlosson        DLangford WGKennedy       WJRoss

Dear Mr. Mcdonald:

WHazelton JVoglewede

SUBJECT:

EVALUATION AND STATUS OF LICENSE CONDITIONS FOR JOSEPH M. FARLEY UNIT 2 By -letters dated February 8 and October 19, 1982, and January 7, 1983, which superseded the October 19, letter, you requested that certain license conditions be formally closed by the NRC. By letter dated October 22, 1982, you noted that another license condition was satisfied. We have completed our reviews of these submittals. The enclosure to this letter indicates the current evalu ion and status of our review of your submittals relating to the identiff license conditions for Facility Operating License No. NPF-8 dated March , 1981. At a future date, along with a routine license amendment, we wi . annotate the conditions with a reference to this letter and/or ny other closecut letter for each specific license condition. Thus, the mended license conditions will provide a record of your compliance with e license conditions and our safety evaluations of each. No response to this letter is required. owever, you may. contact the NRC Project Manager, Mr. Edward A. Reeves, 301-492-7386, should you have any

   -questions.

ncerely, Steven A..Varga,. Chief Operating. Reactors Branch #1 Division of' Licensing

Enclosure:

As stated cc w/ enclosure: See next page

                    *See pr ious white fo       currence 0RB#1:DL           ORB.1:DL*      OR g L BC-0RB#1:DL CParrish           MSlosson;ps    ER eyes    SVarga 3Ag85              3/485 2            3/)2f85    3/ /85

e Docket Nos.'50-348 DISTRIBUTION

                        'and.50-364                Docket File         BGrimes NRC PDR             JPartlow L PDR                MSlosson                                 4 Gray File Mr. R. P. Mcdonald                    ORB #1 Rdg Senior Vice President                 DEisenhut Alabama Power Company                 OELD Post Office Box 2641-                 CParrish .

Birmingham, Alabama 35291 EReeves(2) ACRS (10)

Dear Mr. Mcdonald:

EJordan

SUBJECT:

EVALUATION AND STATUS-0F LICENSE CONDITIONS FOR JOSEPH M.-FARLEY UNIT 2. By . letter dated February 8 and October _19,1982,_ a January.7, 1983, which superceded the- October 19 letter, you requested tJrat certain-license conditions be formally closed by the NRC.: We h de completed our reviews of these submittals. , The enclosure to this letter indicates the ' rrent evaluation and status of our review of certain identified license c ditions issued with Facility 981. Operating License a routine license No. NPF-8 we amendment, on March will anp31,dtate the conditions with aAt a future date along reference to this letter and/or any cl seout letter for the specific license condition. _. No response' to. this letter is requ. ired. However, you may contact the NRC Project Manager, Mr. Edward A. R ves, at~301-492-7386 should you have any Steven A. Varga, Chief-Operating Reactors Branch #1 Division of Licensing

Enclosure:

As stated cc-w/ enclosure: ORB #1:DL See next p ge CParrish

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Docket Nos. 50-348 DISTRIBUTION and 50-364 Docket File NRC PDR JNGrace L PDR Gray File '

                                                                                 /

Mr. R. P. Mcdonald ORB #1 Rdg

   -Senior Vice President            DEisenhut Alabama Power Company           0 ELD Post Office Box 2641            CParrish Birmingham,L Alabama 35291      EReeves(2)

ACRS (10)

Dear Mr. Mcdonald:

EJordan

SUBJECT:

~ EVALUATION AND STATUS OF LICENSE CONDITIONS FOR JOSEPH M. FARLEY UNIT 2 By letter dated February 8 and October 19, 1982, and Jyluary 7,1983, which superceded the October 19 letter, you requested that pertain license conditions be formally closed by the NRC. By letter 1982, you also advised us that you met another                  refpr/ dated October 21 enced license condition. We have completed our reviews of these submittals.

Theenclosuretothisletterindicatesthecurre/ nt evaluation and status of our review of certain identified license conditions issued with Facility Operating License No. NPF-8 on March 31, 1981. At a future date along with a routine license amendment, we will annotafe the conditions with a reference to this letter and/or any closeo'ut letter for the specific license condition. No response to this letter is required. However, you may contact the NRC Project Manager, Mr. Edward A. Reev s, at 301-492-7386 should you have any Steven A. Varga, Chief Operating Reactors Branch #1 Division of Licensing

Enclosure:

As-sta{ed cc w/ enclosure: See next-page

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  ,      Mr. R. P. Mcdonald                                           Joseph M. Farley Nuclear Plant 6
       . Alabama Power Company                                        Units 1 and 2 cc: Mr. W. O. Whitt                                          D. Biard MacGuineas, Esquire Executive Vice President                             Volpe, Boskey and Lyons Alabama Power Company                                918 16th Street, N.W.

Post Office Box 2641 Washington, DC 20006 Birmingham, Alabama 35291 Charles R. Lowman Mr. Louis B. Long, General Manager Alabama Electric Corporation Southern Company Services, Inc. Post Office Box 550 Post Office Box 2625 Andalusia, Alabama 36420 Birmingham, Alabama 35202 Dr. J. Nelson Grace

               ' Houston County Commission                            Regional Administrator - Region II Dothan, Alabama 36301                                U.S. Nuclear Regulatory Comission 101 Marietta Street, Suite 2900 Atlanta, GA 30303 George F. Trowbridge, Esquire Shaw, Pittman, Potts and Trowbridge                   Ira L. Myers, M.D.

1800 M Street, N.W. State Health Officer Washington, DC 20036 State Department of Public Health State Office Building Chairman Montgomery, Alabama 36130 Houston County Commission Dothan, Alabama 36301 Robert A. Buettner, Esquire Balch, Bingham, Baker, Hawthorne, Williams and Ward Post Office Box 306 Birmingham, Alabama 35201

               . Resident Inspector U.S. Nuclear Regulatory Comission Post Office Box 24 - Route 2 l

Columbia, Alabama 36319 State Department of Public Health ATTN: State Health Officer State Office Building Montgomery, Alabama 36104 Regional Radiation Representative EPA Region IV 345 Courtland Street, N.E. Atlanta, GA 30308 n ,, ,-e ,: - - - - e e , ,,vo-- --, . - , - - - - - - - - - - g ,- n - e ,

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EVALUATION AND STATUS OF CERTAIN LICENSE CONDITIONS JOSEPH M. FARLEY NUCLEAR PLANT UNIT 2 DOCKET NO. 50-364 INTRODUCTION Alabama Power Company (APCo) requested that the NRC fomally close out ten license conditions which it considers completed. The requests were by letter dated January 7,1983, which superseded its letter dated October 19, 1982. Also, APCo by letter dated February 8,1982, requested deletion of the license condition relating to the main steam turbine rotor replacements. By letter dated October 22, 1982, APCo advised the NRC that PAD 3.3 was applicable to subsequent fuel cycles thus satisfying another license condition. Our evaluation of your submittals and status of each of these license conditions follows: , DISCUSSION AND EVALUATION

1. Environmental Qualification (EQ) of Electrical Equipment - License Condition 2.C.(18)

, The license condition required certain remedial actions or alternative actions no later than June 30, 1982. Consnission regulation 10 CFR 50.49 negated the June 30, 1982 completion date. By letter dated December. 13, 1984, we provided a safety evaluation which concludes that

the EQ Program is in compliance with the requirements of 10 CFR 50.49.

Therefore, License Condition 2.C.(18) has been met.

2. Ins)ection of Main Steam Turbine Rotor Discs for Cracks or Replacement of (otors - License Condition 2.C.(19)(d)

In February 1980, we informed licensees with Westinghouse turbines that stress corrosion cracks were being observed in the keyway and bore regions of low-pressure turbines. Since the mechanisms associated with the initiation and growth of these types of cracks were not well known I at that time and because we believed these cracks would increase the probability of disc failure, we requested APCo to perform ultrasonic inspections of the rotors of Unit 1. This unit was inspected during November and December 1980 and found to have significant disc cracks even though the plant had operated for only two fuel cycles (approximately 17,000 hours). l-Because of the similarity of metallurgical and operational characteristics of the turbine discs in Farley Units 1 and 2, we i included License Condition 2.C.(19)(d) for Unit 2 to assure that an inspection would be made at the first refueling outage. The inspection

V would determine if similar cracks occur at an earlier time in machine life. Thus, License Condition 2.C.(19)(d) required that the low-pressure turbines be inspected for. keyway and bore cracks in the turbine discs during the first refueling outage or the turbine discs be replaced. APCo proposed by-letter dated February 8,1982 that these inspections be made on a schedule recommended by the turbine vendor-(Westinghouse) using criteria that have been reviewed and approved.by the NRC staff. APCo has followed the Westinghouse inspection schedule and criteria for rotor disc inspections since that date. APCo chose to replace the Unit 2 rotors during its first refueling outage (October 1982). During the fifth refueling outage completed April 24, 1984, Unit I rotors were again replaced.

             .Therefore, APCo has met License Condition 2.C.(19)(d).

3. Schedule for Facility to be in Compliance with Regulatory Guide 1.97 Revision 2 - License Condition 2.C.(20)

The license condition required that prior to April 30, 1981, the licensee shall provide a schedule for bringing Unit 2 into compliance with Revision 2 of R.G. 1.97. By letter dated March 30, 1981 APCo provided such a schedule. Subsequently, APCo withdrew the schedule by letter dated November 16, 1982, pending issuance of further NRC guidance. This guidance became a part of Generic Letter 82-33, Supplement 1 NUREG-0737. APCo provided a schedule to us by letter dated March 30, 1984. Subsequently, a Confirmatory Order dated June 12, 1984 was issued to APC0 requiring implementation of

installation or upgrade requirements with regard to R.G.1.97 application to Emergency Response Facilities by October 1987.

              -Therefore, License Condition 2.C.(20) has been superseded by the

Confinnatory Order.

4. . Upgrading of Emergency Operating Procedures and Operator Training for Transients and Accident (I.C.1) - License (addition 2.C.(21)(a)

Farley Unit 2 was granted an operating license on March 31, 1981, based in part on a pilot monitoring review of some of the emergency operating procedures.. The procedures, based on the draft Westinghouse Owners'

             . Group (WOG) guidelines available at the time, were found to be acceptable for a full power license (see Supplement 5 to the SER,
             'NUREG-0117). The SER recognized that the procedures might have to be upgraded when the WOG guidelines were approved by the NRC staff.
             ~ 0n that basis License Condition 2.C.(21)(a) required an upgrade of the emergency operating procedures and associated operator training per-NUREG-0737, . Item I.C.1, prior to startup following the first refueling outage. However, Generic Letter 82-33, " Supplement I to NUREG-0737 Requirements for Emergency Response Capability," issued on December 17, 1982, changed the schedule for items (including Item I.C.1) from industry-wide implementation dates to plant-specific schedules to be negotiated with each licensee. The licensee responded with a proposed integrated schedule on April 15, 1983, which included a commitment to implement procedures based on NRC approved WOG guidelines.

Subsequently, by letters dated August 5 September 22, and December 15, 4 1983 and April 6, and April 19, 1984 APCo modified several dates in their integrated schedule as a result of negotiations with the NRC staff. A Confirmatory Order was sent to APCo on June 12, 1984 requiring APCo to implement the upgraded E0P's by APCo's commitment date of July 1984 The requirements of the License Condition 2.C.(21)(a) are fully contained within the scope of Item I.C.1 of Generic Letter 82-33. Therefore, License Condition 2.C.(21)(a) has been superseded by the Confirmatory Order.

5. Reactor Coolant System' Vents (II.B.1) - License Condition 2.C.(21)(b)

This license condition required submittal of a designed description and operating procedures for the reactor coolant system vents by July 1, 1981, and a complete installation by July 1,1982. Our letter dated November 7, 1983, advised APCo that the im been superseded by 10 CFR 50.44(c)(3)(iii)plementation schedule has Based on our November 7,~ 1983, letter to APCo License Condition 2.C.(21)(b) has been superseded by NRC regulations.

6. Inadequate Core Cooling Instruments (II.F.2) - License Condition 2.C.(Zl)(g)

This license condition required that APCo provide detail design information and test results from tests of Farley Unit I reactor water level instruments by July 1, 1981. Also the condition further required a planned program to complete instrument development to determine the feasibility of the proposed neutron detector water level instrument by January 1,1982. By letter dated June 24, 1981 APCo provided the EPRI test report (part 2 of license condition) of the non-invasive reactor water level instrument completing that part of the license condition. Generic Letter (GL) 82-28 superseded parts 1 and 3 of the license condition. APCo responded to GL 82-28 by letter dated March 10, 1983, which is i under NRC staff review. Therefore, License Condition 2.C.(21)(g) has been met.

7. Analysis of Thermal Mechanical Conditions (II.K.2.13) - License Condition 2.C.(21)(h)(1)

This condition states that prior to January 1,1982, the licensee is required to submit a detailed analysis of thermal mechanical conditions in the reactor vessel. License Condition 2.C.(21)(h)(1) involves an extended loss of all feedwater, thus, this condition is related to feed Issue and (USI)bleed A-45, cooling Decay Heat of the core and Removal. hence License to Unresolved Condition 2.C.(21) Safety (h)(1) is also related to USI A-49, Pressurized Thermal Shock. The staff will resolve USI's A-45 and A-49 as schedules allow after FY-84.

                                                  .4-The staff finds that License Condition 2.C.(21)(h)(1), which is only one part of TMI Action Plan Item'II.K.2.13, has been completed by the licensee as part of the submittals of the generic effort by the Westinghouse Owners Group (WOG).      In December 1981 WOG' submitted to the NRC WCAP 10019, " Summary Report on Reactor Vessel Integrity for Westinghouse Operating Plants." The NRC staff issued a Safety Evaluation to'APCo on June 18, 1984 closing out Item II.K.2.13.

However, as stated in the June 18, 1984 letter, should the resolution of USI's A-49 and A-45 result in any changes to the conclusions provided in the Safety Evaluation or require any additional actions re. lated to II.K.2.13, APCo will be notified. Therefore, License Condition 2.C.(21)(h)(1) has been met. 8.. Potential for Voiding in the Reactor Coolant System during Transients (II.K.2.17) - License Condition 2.C.(21)(h)(2) This condition required that the licensee provided an analysis of the potential transients. for voiding Section 22.5in ofthe SERreactor coolant Supplement system during(anticipated 5, NUREG-0117 page 22.5-28) of March 1981 refers to this item in NUREG-0737. By letter of January 7, 1983, the licensee stated it was in compliance with this requirement by referencing a submittal of April 20, 1981, from the WOG. The staff reviewed that submittal and a supplemental letter from Westinghouse of February 16, 1983. By letter dated January 10, 1984, we advised APCo of acceptance of the Westinghouse

,              transient analysis for Farley Units 1 and 2.

[ Therefore, License Condition 2.C.(21)(h)(2) is completed.

9. Automatic Trip of Reactor Coolant Pumps (RCP's) (III.K.3) - License l

Sondition 2.C.(21)(1)(2) i-This condition related to the B&O Task Force recomendation II.K.3 relating to automatic trip of the RCP's for a small break LOCA. By NRC Generic Letter 83-10d dated February 8,1983, we established criteria-for license considerations based on model comparisons with LOFT test L3-6 results. In response to this action the licensee provided its plans and schedules in a-letter of April 22,1983, " Generic Letter'83-10d and NUREG-0737 Item II.K.3.5." The-plans and schedules include the following:

                     .(1) a generic submittal to be developed by the WOG, and (2) a plant-specific evaluation to be submittal to NRC within 90-days after licensee receipt of the WOG submittal.

Subsequently, by letter dated April 3, 1984, APCo stated that the WOG submittals are complete by letters OG-110, dated December 1, 1983, and l OG-117 dated March 12, 1984. Also, APCo advised that the WOG Emergency Response Guidelines for procedure revisions with an appropriate manual trip of the RCP's resolves all issues associated with this generic

     ,                                                                                                             1 a                 issue. The schedules for the plant specific emergency operating procedures is included in Confirmatory Order dated June 12, 1984.

Therefore, License Condition 2.C.(21)(i)(2) has been superseded by the Confirmatory Order relating to schedules for NUREG-0737, Supplement 1 items.

10. Revised Small-Break LOCA Analysis (II.K.3.30) - License Condition 2.0.(21)(1)(4)

This condition required the licensee to respond to another recommendation of the B&O Task Force, item II.K.3. A revised small break LOCA analysis ~was to be submitted, using the revised model, by January 1, 1982. However, APCo confirmed in letters of March 26 and June 4, 1982'and January 7, 1983 that it is participating in an effort by the WOG to resolve Item II.K.3.30 of NUREG-0737, " Clarification of TMI Action Plan Requirements," November 1980. The WOG has submitted a revised small break LOCA model to the staff which was approved on May 21, 1985. Therefore, the first part of License Condition 2.C.(21)(1)(4) is considered satisfied. The second part of this license condition required the licensee to submit plant specific calculations, using the NRC approved revised model, by January 1-1983. However, the NRC revised the schedule to allow all licensees one year after approval of the WOG model to submit specific calculations to the NRC in NUREG-0737, page 3-179 item (4). The staff will determine conformance to 10 CFR 50.46 limits (per

               -NUREG-0737, page 3-180) at that time.

Therefore, License Condition 2.C(21)(1)(4) in its entirety would be considered

• satisfied upon completion of NUREG-0737 Item II.K.3.31.

11. Fire Protection - License Condition 2.C.(6)

License Condition 2.C.(6) describes the basic elements of the Farley 2 Fire Protection Plan. As a result License Condition 2.C.(6) will be retained in the license.

          -12.  @ nry Walls - License Condition 2.C.(16)

By letter dated November 19, 1982 APCo revised their October 19, 1982 request to delete License Condition 2.C.(16). APCo requested that License Condition 2.C.(16) be revised rather than deleted. Amendment No. 21 to License No. NPF-8 for the Joseph M. Farley Nuclear Plant, Unit No. 2, revised 2.C.(16) to require modifications to Masonry Wall 2 CBW-34 prior to startup following the second refueling. The licensee advised the NRC staff that the modification was completed during the second refueling outage which was completed on October 22, 1983. Therefore, License Condition'2.C.(16) has been met.

6-b

                                 - 13. Use of PAD 3.3 Fuel Performance Code - License Condition 2.C.(19)(a)                                                                                    !

, 'The condition required that APCo provide additional evaluations of the Westinghouse fuel perfomance code, PAD 3.3, to demonstrate its applicability during successive fuel cycles. PAD 3.3 was used in the

                                            - safety analysis of. Farley 2. This code was approved with four restrictions -described in our safety evaluation of February 9,1979.
                                             - sent to Westinghouse. Three of these restrictions deal with numerical
                                            - limits and have been complied with. The fourth restriction relates to the use of-the PAD 3.3 code for the analysis of fission gas release i..                                             from uranium dioxide (UO,,) for power increasing conditions during normal operation. This Pestricting applies to the safety analysis of

• Farley 2. However, Westinghouse stated that this restriction did not adversely affect the results of the safety analyses perfonned for Farley. In addition, Westinghouse prepared and submitted a detailed evaluation of this restriction in Addendum 1 (September 1979) to WCAP-8720.

At the time the Farley Safety Evaluation Report, Supplement 5, was g issued, our review of Addendum 1 to WCAP-8720 had not yet been r completed. However, because the fission gas inventory in the fuel is

- low during the first cycle of operation, this restriction was not i . expected to have a significant impact early in core life. For this 4

reason, the fuel thermal design for Farley Unit 2 was found acceptable for the first fuel cycle, but a condition was placed on the operating

license to require resolution of the issue prior to subsequent cycles-

! of operation. - 1

                                            . By letter dated July 20, 1982, we informed Westinghouse that our review of Addendum 1~to WCAP-8720 had been completed and the report was found

to be' acceptable for reference in license applications. Our evaluation

, also concluded that the restriction related to fission gas release was . unnecessary and should be eliminated from applications involving the j- PAD 3.3 code. By letter dated October.22, 1982 APCo cited the approved version of Addendum 1 to WCAP-8720 (including responses to NRC requests for information) as a basis for the continued applicability of the PAD 3.3 code to successive fuel cycles'at Farley Unit 2. Since our approval of l Addendum 1 results in a less severe set of restrictions than those applied previously in the PAD 3.3 analysis of the subsequent fuel cycles, we agree that Addendum I satisfies our concerns and that License Condition 2.C.(19)(a) has been met. ., l' ' f-i i L ' i c= v ~ e- v 4 Sw,-,.wv, re-w-- w

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SUMMARY

We conclude that the licensee responses and action taken to the license conditions, noted above, indicates compliance with the conditions as noted. Facility Operating License NPF-8 for Farley Unit 2 will be so annotated at a future date as administrative changes. Date: May 23,1985 PRINCIPAL CONTRIBUTORS: E. A. Reeves D. Langford W. G. Kennedy W. J. Ross W. Hazelton M. Slosson J. Voglewede i $}}